The Mexican treasury can apply precautionary attachments when there are fiscal credits not guaranteed by the taxpayer or when the guarantee is insufficient to cover them.
To guarantee the payment of a tax credit, the Tax Administration Service (SAT) ordered the seizure of bank accounts of the Mexican company Alsea, owner of multinational franchise restaurants.
The company that manages franchises of chains such as Starbucks, Domino’s Pizza, and Burger King, reported in April that the SAT notified it of the obligation to pay 3,881 million pesos in taxes derived from the purchase of the Vips chain in 2014.
In 2021, Alsea registered another relevant tax credit for the companies purchased from the Italianni’s chain. Both debts are still in litigation but the SAT can apply precautionary attachments when there are tax credits not guaranteed by the taxpayer or when the guarantee is insufficient to cover them.
As we reported, the treasury authority applied the embargo at the end of last May and the company filed an injunction to challenge it.
In the middle of last June, a judge granted a definitive suspension against the embargo, which allows Alsea to access all the funds in its accounts in Santander, BBVA and Citibanamex while the trial is being processed, as long as it guarantees the amount of the tax credit. .
As we mentioned, Alsea received a notification from the treasury regarding the resolution of the appeals for revocation that it has filed against the liquidation letters in which the SAT demands the payment of taxes for alleged income in the acquisition of goods, derived from the purchase of the Vips restaurant division from Walmart de México, in 2014.
However, the company considers that it does not have to show a guarantee because it is litigating in parallel the nullity of the tax credit, says Reforma .