The Supreme Court of Justice of the Nation (SCJN) has upheld a tax ruling against Primero Empresa Minera, a subsidiary of First Majestic Silver Corp., confirming the company’s obligation to pay 2.87 billion pesos (approximately USD 155 million) related to income tax and the single-rate business tax (IETU) for the 2012 fiscal year, including surcharges, updates, and fines.
The unanimous decision by the Court’s full bench approved a draft opinion authored by Justice Lenia Batres Guadarrama, overturning a previous February ruling by then-president Norma Piña Hernández, which had admitted First Majestic’s appeal for review (276/2025). The Court dismissed the appeal after resolving claim 105/2025 filed by the Ministry of Finance and Public Credit (SHCP), siding with the Treasury’s argument that the case did not raise issues of exceptional constitutional or human-rights interest.
Justice Batres noted that the company had requested to postpone the resolution while negotiating with tax authorities, but the Court found no legal basis to grant such a delay.
“There is no mechanism within the regulations that allows for a postponement, so we maintain the resolution as drafted,” she stated.
The Court also referenced prior precedents regarding the same provisions of the Federal Tax Code, which had already been reviewed and resolved in earlier cases.
In a related matter, on October 23, 2025, the SCJN imposed a fine of 70 UMA (roughly 8,000 pesos) on Primero Empresa Minera for filing an unfounded motion to recuse Justice Yasmín Esquivel Mossa, describing the action as an attempt to delay proceedings.
“It is clear that they do it to prolong the conflict,” said Justice María Estela Ríos González, emphasizing the need to deter procedural tactics that hinder the Court’s efficiency.
As of publication, First Majestic Silver Corp. has not issued an official statement regarding the Supreme Court’s decision.
Original Article: https://www.mexicominingcenter.com/mexicos-supreme-court-upholds-tax-ruling-against-first-majestic-subsidiary/
