Supreme Court Re-Opens Coca Cola Tax Debt
This article by Lucía Castillo originally appeared in the November 23, 2025 edition of Polemón.
Mexico’s new Supreme Court of Justice of the Nation (SCJN) made a historic decision and took up a case that it had rejected a week earlier.
At the request of Minister Lenia Batres Guadarrama, the Plenary of the Court resolved to take up the review of an alleged multimillion-dollar tax debt of the company FEMSA.
It was on November 6 when, by eight votes against one (Batres’s), the SCJN rejected the request of a collegiate court to take up the review of an amount of 2 billion 868 million pesos, levied against FEMSA, owner of the Oxxo chain, for taxes allegedly omitted in the 2011 fiscal year.
However, the decision changed on November 13, the day on which, by a vote of six to three, the Court agreed to take up the same case, but now at the request of Minister Batres Guadarrama.
In both cases, the attraction due to the large amount of the tax review appeal 320/2024, of the Twentieth Collegiate Court in Administrative Matters, “Is the appeal for tax review appropriate in order to issue a substantive ruling, in the event that the amount exceeds the legal limit provided, so that in tax debts of extraordinary amount, they are definitively resolved by the Federal Judicial Branch (PJF)?”, was the topic expressed by the Secretary General of Agreements of the Court during the session of November 13.
In general, all matters exceeding 395,000 pesos can be challenged by the Government before the PJF, when it loses the first instance in the Federal Court of Administrative Justice (TFJA).
For decades, the Court has maintained that the economic amount is not enough to justify taking up the case, but now, the FEMSA case could serve to establish that it is indeed responsible for intervening when it comes to multimillion-dollar tax disputes.
By exercising the attraction, the Court will analyze all points in dispute, including the evidence and arguments of the SAT and the company, which won the case in the TFJA, which in June 2024 annulled its alleged tax debt .
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