How Much and When Must Grupo Salinas Pay Its Tax Debt?: SAT

Following the Supreme Court of Justice of the Nation (SCJN) dismissing the final legal appeals filed by Grupo Salinas companies, the Tax Administration Service (SAT) confirmed that the corporate group must settle 51 billion pesos for Income Tax (ISR). The amount will be enforceable starting January 2026, when the tax authority issues the formal payment demand, in accordance with the provisions of the Federal Tax Code (CFF). During this Friday’s morning press conference at the National Palace, the Head of the SAT, Antonio Martínez Dagnino, explained the scope of the judicial resolution, as well as the deadlines and alternatives that the law allows taxpayers to settle these types of debts.

How Long Has Grupo Salinas’s Tax Litigation Been with the SAT?

The case originated from determinations made by the SAT between 2013 and 2018, when the tax authority issued administrative rulings against various Grupo

companies due to the improper application of tax losses. These losses were used to reduce the payment of ISR corresponding to the fiscal years of: -2008 -2009 -2010 -2011 -2012 -2013 According to the SAT, these deductions did not comply with legal criteria, which resulted in the determination of multi-billion peso tax liabilities.

“Between 2013 and 2018, the tax authority determined, through administrative rulings, income tax debts, given that the tax losses used by the companies were improper,” explained Martínez Dagnino.

When Must Grupo Salinas Pay the SAT?

Although the Court’s ruling is now final, payment is not immediate. According to the current legal framework, the SAT must issue a formal payment demand in January 2026. From that moment: -The voluntary payment period begins -The option to request payment schemes according to the law becomes available -The taxpayer can manage adjustments or facilities provided in the CFF Martínez Dagnino emphasized that, once the demand is notified, the taxpayer can request from the tax authority whatever is legally appropriate to fulfill the obligation.

Can There Be Discounts or Adjustments to the Amount?

One of the points that has generated the most attention is the possibility of reductions in the total debt amount. The Head of the SAT clarified that the Federal Tax Code contemplates this scenario under certain conditions. According to the regulations: “In case of intent to settle the debt, taxpayers may request from the SAT, depending on the payment order and scheme, downward adjustments of up to 39%, in accordance with the law and court rulings.” This means that, if Grupo Salinas opts for a specific payment scheme and meets the established requirements, the final amount could be reduced, always within legal limits.

During his statement, Martínez Dagnino reiterated that the payment of taxes is not optional, but a constitutional obligation. Based on Article 31, Section IV, of the Constitution, all individuals and legal entities are obligated to contribute to public expenditure in a proportional and equitable manner. “We invite these companies to make the corresponding payments,” the official stressed, emphasizing that the case is being handled strictly according to the law.

This is a Legal, Not Political, Matter: Sheinbaum

For her part, President Claudia Sheinbaum Pardo was emphatic in stating that the Grupo Salinas case does not have political overtones, but rather responds to a legal and administrative process that has followed its institutional course. “It is a strictly legal, judicial, and administrative matter. The Court ruled, notification will be in January, and these companies have the right, given the prior court rulings, to request discounts according to the Tax Code,” she stated. The president added that the federal government expects the debt to be settled once the demand is formalized.