Mexican Court Holds GAAR Cannot be Applied Retroactively But Older Transactions Lack Economic Substance May Still be Disregarded
According to recent reports, the Ninth Metropolitan Regional Chamber of the Federal Court of Administrative Justice issued a decision on 28 April 2023 regarding required economic substance and the retroactive application of Mexico's general anti-avoidance rule (GAAR), which was introduced with effect from 1 January 2020. Under the GAAR, the tax administration (SAT) is essentially empowered to r…
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