Patricio Sandoval
Associate
Patricio Sandoval is a tax and business lawyer. He specializes in tax controversies, representing clients in federal tax disputes such as audits, administrative appeals, alternative dispute resolution proceedings, and international tax issues, as well as tax litigation including nullity actions before federal administrative courts and constitutional challenges (amparo) before federal courts of appeals and the Mexican Supreme Court, in cases against local and federal tax agencies.
Patricio is also experienced in tax consultancy, analyzing Mexican laws and regulations to strategize on the tax effects of corporate transactions involving domestic and international companies.
Representative Experience
- Assisted clients in the automotive sector with the filing of Mutual Agreement Procedure (MAP) requests before the Large Business Section of the Tax Administration Service.
- Represented manufacturing sector clients obtaining income and value-added tax refunds from the Administrative Court.
- Represented clients in government procurement and bidding processes.
Community Involvement
- Assistant Professor of Tax Law and Administrative Litigation, Universidad La Salle
- Volunteer, Fundaci贸n Pro Ni帽os de la Calle
Presentations and Publications
- Author, 鈥淥bligation to register in the Mexican Federal Taxpayer Registry for individuals as of June 2023,鈥 La Salle Law Review (August 28, 2023)
Languages
- Spanish
- English
New Criteria for Tax Audits and Refunds: Greater Tax Certainty for Your Business
Recently, Mexico鈥檚 Ministry of Finance (SHCP) published the 鈥淎greement Establishing General Criteria and Operational Guidelines of an Advisory Nature to Promote Productive Investment and Tax Compliance.鈥 In practice, this instrument aims to foster a clear and predictable tax environment, streamline administrative procedures, encourage investment, and provide greater certainty in tax audits and refund processes. This is particularly significant in light of the upcoming review of the United States-Mexico-Canada Agreement (USMCA) and the growing interest in attracting both domestic and foreign capital to operate in Mexico.
Mexican Supreme Court Validates the Blocking of Bank Accounts
On April 6, 2026, the Mexican Supreme Court (鈥淪CJN鈥), when ruling on the constitutional challenge (acci贸n de inconstitucionalidad) 58/2022, recognized the constitutionality of Article 116 Bis 2 of the Credit Institutions Law (鈥淟IC鈥), validating the blocking of bank accounts by the Mexican Ministry of the Treasury, through its Financial Intelligence Unit (鈥淯IF鈥), based on the 鈥淏locked Persons List鈥 when there is sufficient evidence to believe that these persons are involved in crimes of (i) terrorist financing, (ii) operations with illicit funds, or (iii) related offenses. This precedent is of particular relevance for anyone who maintains bank accounts or performs transactions through the Mexican Financial System.
The System for Securing Tax Debts Contested by Taxpayers Made More Flexible
On April 9, 2026, a crucial amendment to Mexico鈥檚 Federal Tax Code (CFF) was published, restoring taxpayers鈥 ability to choose the type of tax guarantee that best suits their needs when securing tax liabilities and thereby avoiding collection actions by the tax authority while any defenses filed are being processed. This gives taxpayers back control over the protection of their interests while litigation regarding tax debts is ongoing.
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Mexico Plans to Reactivate Fracking by 2027
President Claudia Sheinbaum announced on April 8 a significant shift in Mexico鈥檚 energy policy by unveiling a project to exploit natural...
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U.S. FinCEN's Order Targeting CIBanco Will Upend Mexican Fiduciary Market
In late June 2025, the U.S. Treasury's FinCEN (Financial Crimes Enforcement Network), under new authorities granted pursuant to the...
President Trump鈥檚 Tariffs Announcement and their Impact on Mexico
On April 2, 2025, U.S. President Donald Trump announced his tariff policy for numerous countries. In the case of Mexico, exported products that comply with the USMCA regulations are exempt from tariffs, which are approximately half of Mexico鈥檚 exports to the United States.