GM Faces MX$1.8 Billion Tax Liabilities Amid Mexico Legal Reforms

General Motors (GM) faces unresolved tax liabilities in Mexico totaling nearly MX$1.8 billion (US$97.3 million), amid reforms to the Ley de Amparo—a constitutional mechanism protecting individuals and companies from government actions that may violate their rights. The changes could limit companies’ ability to contest federal tax claims. The issues span federal and local jurisdictions and involve both corporate income and property taxes.

In March 2024, the Federal Tribunal of Administrative Justice (TFJA) confirmed two tax credits against GM totaling MX$1.8 billion. The first, MX$1.197 billion, was levied in June 2016 on Controladora General Motors for unpaid consolidated corporate income tax (ISR) corresponding to 2008. The second, MX$603 million, dates to June 2017 and concerns ISR for 2011. 

The recent reform to the Ley de Amparo, approved by the Senate on Oct. 15, 2025, seeks to prevent the law from being used to delay tax collection. Under the new rules, companies seeking amparo against SAT tax claims can suspend collection only if they provide a guarantee covering the fiscal interest—either through a deposit at Banco del Bienestar or a letter of credit from an authorized financial institution. Legal analysts summarize: “Suspension is only possible if the taxpayer either deposits the owed amount or secures a financial guarantee from a bank.”

The reform also restricts companies from litigating cases already pending before the TFJA—a tactic previously used to delay payments. This affects major corporations with confirmed tax credits, including GM. Other high-profile cases include Codere, Elektra, and Canadian miner Primero, where Supreme Court review is increasingly limited to constitutional issues rather than the factual merits of each claim.