Against a determined tax credit, the file decides
We do not keep our clients' books. We assess the tax effect of their transactions and intervene where that effect is determined: in the interpretation of the norm, in the structuring prior to the act, and in the defence against determinations of the tax authority.
No tax defence is improvised on the day the assessment is served.
By the time the notice of observations or the determining resolution is served, the margin is already fixed by what the taxpayer is able to produce. Materiality is proven with the deliverable that was preserved, business purpose with the memorandum drafted before the decision was taken, and the flow of funds with the reconciliation between contract, tax receipt and payment that someone kept current. Evidence built after service carries the weight of its own date.
We therefore work the tax front in two stages: we build the evidentiary file while the transaction is taking place, and we defend it when the authority questions it. A firm that appears only at the second stage litigates with whatever it finds.
Six fronts of tax practice.
Defence against determined tax credits.
Administrative appeal, filed through the tax mailbox within the statutory period running from service; contentious administrative proceedings before the Federal Court of Administrative Justice; and direct and indirect amparo. We suspend the administrative enforcement procedure and structure the security of the tax interest so that the defence does not consume the company's liquidity.
Conclusive agreements and early resolution.
Where settlement is preferable to litigation, we conduct the conclusive agreement before the Taxpayer Defence Attorney's Office, with remission of penalties on the first occasion where applicable and definitive effect over the facts agreed, which are no longer open to further assessment.
Defence of materiality and of article 69-B.
The presumption of non-existent transactions is not rebutted with arguments but with a file, and within a period that is granted once: fifteen days from service, extendable a single time by five more. Deliverables, acceptance records, logs, reconciliation between contract, tax receipt and payment, and demonstrable capability on the part of the counterparty.
Express home visit and presumption of false receipts (49 Bis).
Since 2026 the authority may verify the issuance of false receipts through a summary procedure: five business days to produce evidence, fifteen for the resolution, twenty-four business days in total from the order to the outcome. Where the presumption stands, the digital seal certificate is cancelled and the recipients of those receipts have thirty calendar days to correct their position before their own certificate is restricted. That file is not assembled in five days: it is assembled beforehand.
Refunds, offsets and filings.
Recovery of favourable balances, defence against express refusal and against negativa ficta, and conduct of filings before the authority, including certification of account statements for the treatment of enforceable instruments.
Strategic taxation and international tax.
Planning within the framework of the norm, transfer pricing and supporting documentation between related parties, tax compliance, and analysis of the tax effect of each transaction before it is executed.
The tax consequence is decided before the transaction, not after.
A dedicated unit for the recurring tax function of the company and of the group: structuring, reorganisation, international position, transfer pricing and compliance. Six lines of work, under the same evidentiary standard as the defence practice.
Structuring of transactions and divestitures.
Taxable and tax-free acquisitions, mergers, spin-offs, contributions in kind, joint ventures and disposals. Determination of tax basis, effects on the transfer of shares and the corresponding statutory report, so that the tax consequence is settled before the instrument is signed and not after it is questioned.
Corporate reorganisations.
Design and implementation of reorganisations within the group, obtaining the authorisations required where the transaction calls for them, and preservation of tax attributes —losses carried forward, net tax profit and contributed capital accounts— under a demonstrable business purpose.
International tax and treaty application.
Inbound and outbound investment structuring, application of the treaties for the avoidance of double taxation and their limitation-on-benefits provisions, beneficial ownership, permanent establishment analysis, crediting of tax paid abroad, and preferential tax regimes.
Transfer pricing.
Supporting documentation between related parties, functional and comparability analysis, local, master and country-by-country filings, and advance pricing agreements where the exposure justifies negotiating the criterion in advance rather than defending it later.
Compliance, statutory report and tax position.
Determination and payment of federal and local contributions, informative filings, the statutory tax report, effective tax rate, and the accounting tax provision with its reconciliation, so that what is reported and what is recorded say the same thing.
Indirect taxes and financing.
Value added tax and excise duties in complex transactions, crediting, refunds and favourable balances; and the tax treatment of debt and equity —thin capitalisation, deductibility of interest and hybrid instruments— in intragroup treasury operations.
The return is the last step. What defends it is the accounting behind it.
The recurring accounting and compliance function of the company and of the group, operated under the same evidentiary standard as the defence practice: what is recorded must be capable of proving the transaction it represents.
Managed tax and accounting compliance.
Bookkeeping, determination of taxes and deferred items, financial information under NIF, IFRS or US GAAP, filings and notices before the tax administration, and the disclosure of reportable schemes.
Outsourced accounting, payroll and treasury.
The accounting function operated end to end: bookkeeping, payroll and employer obligations before the social security and housing institutes, treasury and electronic invoicing. The company keeps the decision; the firm takes the execution.
Audit, assurance and statutory opinion.
Financial and tax audit, the statutory tax opinion and the informative return on tax position, and financial due diligence when a transaction requires the numbers to be examined before it is signed.
Accounting certification of account statements.
Certification by a public accountant of the account statement required to assemble or strengthen an enforceable instrument, and the expert support for the balance when it is disputed.
Tax technology and connected compliance.
Automation of recurring obligations, an obligations dashboard by entity and by period, and reconciliation between what was invoiced, what was recorded and what was filed, over the Digital Legal Management Ecosystem.
Transition of the accounting function.
Taking over the function from an outgoing firm without losing history: reconciliation of opening balances, recovery of files, review of outstanding obligations and a documented handover, so that a change of adviser does not become a gap in the record.
Nine scenarios, nine routes of defence.
Each audit or collection action has its own route, its statutory period and its strategy. Move around the dial to see how each one is conducted.
No matter is resolved within a single discipline.
Do you have a matter to review?
Describe the matter in three lines. We will tell you plainly whether it is one we can take on.
International Firm of the Year 2022 — Tops México ranking, Los Mejores Abogados de México
Fundación Teletón — recognition on national television for pro bono counsel, 2025
Av. Insurgentes Sur 1425, floor 7
Colonia Insurgentes Mixcoac
Alcaldía Benito Juárez
Mexico City, C.P. 03920
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