This article by Ivan Evair Saldaña originally appeared in the November 20, 2025 edition of La Jornada, Mexico’s premier left wing daily newspaper.
Mexico. The Supreme Court of Justice of the Nation (SCJN) dealt another blow to Grupo Salinas yesterday, validating the powers of the Tax Administration Service (SAT) to impose a fine of more than 67 million pesos on Nueva Elektra del Milenio for declaring losses greater than the actual ones in the 2012 fiscal year.
The ruling comes a week after the Court definitively ratified seven other tax assessments totaling more than 48 billion pesos against Ricardo Salinas Pliego’s conglomerate. However, it left pending the ninth tax dispute, amounting to 621.9 million pesos, which was to be resolved based on the draft opinions of Justices Lenia Batres Guadarrama and Yasmín Esquivel Mossa, whose criteria are contradictory.
By a vote of six to three, the full court approved Lenia Batres’s project, which revoked the injunction granted by the twentieth collegiate court for administrative matters to Nueva Elektra del Milenio—a subsidiary of Grupo Elektra—against the fine of 67,165,827 pesos. Furthermore, it ordered the case returned to the same court for a new ruling, based on the Supreme Court’s criteria.
Nueva Elektra argued that the SAT (Mexican Tax Administration Service) could not audit it directly and that the tax credit should be directed only to its parent company, Grupo Elektra, under the current tax consolidation regime. However, the justices rejected this argument and confirmed that the tax authority can directly audit the companies within a group, even when they file jointly under that regime.
“The verification powers that the tax authorities can deploy are not limited with respect to controlled companies, that is, there is no exception that excludes them from the exercise of the powers of tax verification as can be seen from the provisions of article 42 of the Federal Tax Code in force for the fiscal year 2012,” Batres argued.
The Court also ruled on a motion to recuse filed by Nueva Elektra seeking to remove Batres and Esquivel from the case due to alleged bias. However, the full court unanimously declared the motion unfounded and sanctioned the company with a fine of 300 UMA (34,000 pesos) for acting in bad faith to delay the trial.
The Supreme Court left the conglomerate’s last lawsuit pending, removing from the list two projects concerning Totalplay, one by Batres and the other by Esquivel, which held opposing views.
Salinas Consortium Announces Will Appeal to Other Authorities
“The separation of powers in our country simply no longer exists,” Grupo Salinas accused, after the SCJN ruled on the injunction granted by a collegiate court to Nueva Elektra del Milenio regarding the fine of 67 million 165 thousand 827 pesos.
In a statement, Grupo Salinas asserted that now, at least a decade after litigating its tax credits in court, it is willing to “pay what is fair and correct (…), what we will never do is concede to openly excessive and illegal demands.”
According to the corporation, the resolution of the new plenary of the SCJN regarding the company’s resources was made, “just like a few days ago, by political order and not in accordance with the law.”
Grupo Salinas reiterated that it will seek to fight its case in “other national and international instances,” and insisted that, according to its view, the Supreme Court’s resolutions “are not final.”
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