Tax Litigation

At MNP Consultants we offer specialized legal advice and procedural representation in tax and administrative litigation, supported by a technical, strategic and legally rigorous approach. Our practice includes the comprehensive defense of taxpayers against acts and resolutions issued by tax and administrative authorities at the federal, state and local levels, covering the challenge of tax credits, audits, administrative and sanctioning procedures, as well as controversies arising from the exercise of verification powers. We implement litigation strategies based on a thorough regulatory analysis and the precise application of jurisprudential and doctrinal criteria, aimed at safeguarding the rights and interests of our clients.

We have a multidisciplinary team made up of lawyers and accountants with extensive experience in the interpretation and application of tax, administrative and procedural provisions, which allows us to develop highly precise legal strategies aimed at minimizing risks, reversing improper determinations and comprehensively safeguarding our clients' assets and operational continuity.

Our consolidated trajectory, coverage in several states of the Republic and proven results in highly complex cases position us as a reference in legal defense before tax authorities, providing legal certainty and strategic value to business management.

A comprehensive defense with technical support and national presence

We represent companies before tax and administrative authorities at all levels of government -local, state and federal- intervening in matters ranging from challenging tax credits, audits and in-depth reviews, to highly specialized administrative proceedings such as social security, foreign trade and taxes. Our team thoroughly analyzes each file to identify areas of opportunity, design sound procedural tactics and anticipate potential contingencies. Our practice is distinguished by a preventive vision that reduces contingencies and by a proactive defense that maximizes the probability of success at each stage of the process.

How do we help our customers?

Attention to reviews of opinions, home, office or electronic visits.

Conclusive agreements before PRODECON.

Follow-up on procedures, requests, VAT and income tax refunds.

Attention to the requirements of verification powers (home visit, desk review, electronic review, and certification) and management (in-depth surveillance, letters of invitation).

Complaints and specialized consultations before PRODECON

- Constitutionality of laws, regulations and general norms
- Attention to special procedures for indemnification liability
- Legal advice in administrative proceedings related to penalties for non-compliance with their obligations
- Data and information protection, confidentiality, industrial secrets, personal data.
- Attention to trademark, patent and copyright rights, challenging resolutions that affect their validity or registration.
- Attention to verification visits by federal, state and/or municipal authorities, as well as attention and follow-up to the sanction procedures derived from them.
- State's patrimonial responsibility towards private parties.
- Advice on the application of the Federal Law for the Prevention and Identification of Transactions with Illicit Resources
- Administrative proceedings in the form of lawsuits before municipal, state and federal authorities.
- Administrative lawsuits against federal, state and local authorities.

Confirmation of SAT criteria

Administrative appeals

Nullity proceedings before the Federal Court of Administrative Justice.
Amparo proceedings before District Courts or Collegiate Courts.
Amparos on review before the SCJN.

Our specialized practice areas

✅ Constitutional Law and Amparo

Comprehensive legal defense specializing in constitutional law and amparo proceedings, designed to effectively protect the fundamental rights of our clients against illegal or arbitrary acts of the authorities. Our service is characterized by an exhaustive analysis of the constitutional order and a highly specialized procedural strategy, oriented to the prevention and nullification of acts that violate essential principles such as legal certainty, legality and due process. Through precise legal advice and constant accompaniment, we guarantee a solid and personalized defense to safeguard the interests of our clients at all levels of the judicial process.

How do we help our customers?

Direct and indirect amparo proceedings
Actions of unconstitutionality
Constitutional controversies
Fuzzy control
Amparo proceedings before District Courts or Collegiate Courts.
Amparos on review before the SCNJ.

✅ Social security.

Our practice is oriented to the defense of employers and obligated parties against acts and resolutions by autonomous tax agencies such as the Mexican Social Security Institute (IMSS), the National Workers' Housing Fund Institute (INFONAVIT) and other competent authorities, including the determination of worker-employer contributions, constituent capitals, labor risk premiums, audits and reviews, as well as administrative proceedings and controversies derived from verification and inspection powers in this area.

How do we help our customers?

Review of the cases of occupational accidents, occupational diseases and disabilities that must be taken into account for the determination of the percentage of the premium to be covered by the occupational risk insurance.

In construction, review of compliance with employer obligations contained in the Regulations of the Mandatory Social Security for Construction Workers for a specific work or period of time.
Attention and follow-up of foreclosure proceedings
Presentation of guarantees for the suspension of the administrative enforcement procedure.
Attention and follow-up of audits and auditing procedures (review of reports, self-correction, desk review, invitation letters, regularization).
Administrative appeals before IMSS/INFONAVIT.
Nullity proceedings before the Federal Court of Administrative Justice.
Amparo proceedings before District Courts or Collegiate Courts.
Amparos on review before the SCNJ.

✅ Foreign trade

Specialized legal advice and legal representation in foreign trade and customs law, with a technical and strategic approach, fully supported by the applicable national and international regulatory framework. Our practice focuses on the defense of importers, exporters and other foreign trade operators against acts and resolutions issued by customs and tax authorities, including determinations of taxes and duties, imposition of penalties, audits, verifications of goods in transport, administrative procedures in customs matters (PAMA) and disputes arising from the application of international trade treaties and agreements.

How do we help our customers?

Administrative appeal for revocation

- Administrative litigation
- Indirect or direct amparo proceedings

Administrative Procedure in Customs Matters (PAMA)

- Administrative Proceeding for Omitted Contributions (PACO)

Customs clearance audits and reviews

Determination of omitted contributions (IGI, VAT, DTA, etc.)

Follow-up of verification powers due to incorrect tariff classification

Inaccurate customs valuation

Restriction or non-tariff regulations not complied with

Infringements due to omissions in documentation or declarations

Precautionary seizure of goods.

Outstanding achievements.

Over the 9 years of MNP Consultants, there has been a constant trend of 95% of effectiveness by obtaining rulings that favorably resolve clients' problems, which has represented savings of hundreds of millions of pesos.

Success stories

We solved a client's problem by obtaining the annulment of a tax credit based on an unconstitutional article. Through the exercise of diffuse control, we demonstrated the illegality of the authority's actions, thus eliminating an unfair financial burden and protecting the client's interests in tax matters.
The legal distinction between medicines and herbal remedies was recognized for purposes of the application of the 0% VAT rate. This criterion, supported by evidence and specialized technical arguments, constitutes a favorable precedent and allows the refund of balances in favor of the taxpayer, achieving the refund of amounts requested.
We solved the problem of one of our clients that during the verification powers, evidence was rejected under requirements not provided by law, achieving the recognition of the totality of the deductions made.
In the event of an omission by the State, the obligation to repair damages caused by its irregular activity, without requiring malice or fault, was accredited.
An act of authority that ordered the freezing of all bank accounts of a senior citizen who only received income from a pension, thus ensuring that he had access to all his resources because they were not subject to seizure.
In connection with the freezing of resources to an individual who was unaware of the reason, it was proven in the trial of guarantees that the implementation of the financial blockade was unjustified.
The bank accounts implemented as a precautionary measure were demobilized when the complainant's omissive conduct ceased, and the continuity of the same was excessive.
We solved the problem of a client in the determination of a rectification of an occupational risk premium, by proving that the legal assumption for the percentage increase of the same was not configured.
We solved the problem of a client who was assessed a constitutive capital, after it was proven that the assessment was not appropriate with respect to a general illness of the employee.
Favorable ruling against the determination of omissions for the payment of housing quotas.