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 c…