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 recharacterize transactions that lack business purpose and are entered into for a tax benefit. The case involved an assessment issued in 2021 in respect of service transactions carried out in 2019. The SAT determined that the transactions lacked economic substance and, therefore, the...