{"id":6367,"date":"2026-02-10T21:33:38","date_gmt":"2026-02-11T02:33:38","guid":{"rendered":"https:\/\/guerrerosantana.com.mx\/contracts-executed-abroad-and-their-tax-validity-in-mexico\/"},"modified":"2026-02-10T21:33:38","modified_gmt":"2026-02-11T02:33:38","slug":"contracts-executed-abroad-and-their-tax-validity-in-mexico","status":"publish","type":"post","link":"https:\/\/guerrerosantana.com.mx\/fr\/contracts-executed-abroad-and-their-tax-validity-in-mexico\/","title":{"rendered":"Contracts Executed Abroad and Their Tax Validity in Mexico."},"content":{"rendered":"

On <\/span>January 23, 2026,<\/span><\/strong> a relevant isolated decision was published in the <\/span>Semanario Judicial de la Federaci\u00f3n,<\/span><\/strong> addressing contracts executed abroad and their tax effects in Mexico.<\/span><\/p>\n

This judicial criterion establishes that:<\/span><\/p>\n

Private contracts executed abroad, when intended to produce tax effects in Mexican territory, must comply with the \u201cfecha cierta\u201d requirement under Mexican law.<\/span><\/p>\n

The criterion arose from a case in which the tax authority denied a tax refund, arguing that the contract executed abroad lacked sufficient evidentiary value because it did not meet the \u201cfecha cierta\u201d requirement in accordance with Mexican legislation.<\/span><\/p>\n

The Court upheld this position, stating that even if a contract is executed outside Mexico, when it is used to support tax effects within the country, it must comply with the requirements that make it enforceable against third parties, including the tax authorities.<\/span><\/p>\n

Although this is an isolated decision, it constitutes a guiding criterion that may be relied upon by the SAT and by courts in matters related to:<\/span><\/p>\n