If your company provides drilling, FPSO operation, supply vessels, or technical services in Mexico's oil & gas sector — you may be entitled to recover wrongfully withheld income tax from the past five fiscal years.
Foreign companies operating in Mexico's oil & gas sector routinely overpay income tax due to misclassification of contract payments and incorrect application — or outright non-application — of available bilateral tax treaties.
Bareboat and time charter payments are classified as royalties subject to 25% withholding, when applicable treaty rates — Mexico-Norway, Mexico-Netherlands, Mexico-Singapore, Mexico-US — often cap the rate at 10% or less.
Following recent Supreme Court (SCJN) rulings, payments for technical assistance and specialized services have been recharacterized, exposing companies to unexpected withholding that contradicts established treaty protections.
Even when treaties are in force, withholding agents — including PEMEX and private operators — frequently fail to apply the correct reduced rates, leaving millions in excess tax improperly withheld year after year.
Mexican tax law provides a five-year statute of limitations to file refund claims for wrongfully withheld taxes. For companies operating in Mexico's offshore and onshore oil & gas sector, this window represents a significant and time-sensitive opportunity to recover real capital. Each year without action is a year of exposure permanently lost.
Recovering wrongfully withheld tax requires a precise combination of Mexican tax litigation expertise and deep familiarity with oil & gas contract structures. This is a narrow specialty — and it is the only thing we do.
We review your contracts, historical payments, and withholding records to quantify the potential recovery — at no charge. You will know the opportunity before any engagement.
We identify the applicable treaty provisions and the correct legal characterization of each payment type to build the strongest possible refund claim for your specific contracts.
We file and litigate refund claims before the SAT and, when necessary, before Mexico's Federal Tax Court (TFJA), where I have personally won over 1,000 cases across a range of industries.
Upon successful recovery, we provide guidance to correct the withholding structure going forward — ensuring the problem does not recur in future fiscal years.
For qualified service providers, recovery is pursued on a contingency basis: minimal upfront commitment, with our fees aligned entirely with a successful outcome.
You incur no significant legal fees unless — and until — we recover tax on your behalf. Our incentives are identical to yours.
My boutique practice focuses exclusively on the intersection of Mexican tax litigation and the oil & gas industry — a specialty narrow enough that very few practitioners genuinely command both domains.
I have personally won over 1,000 tax refund cases before Mexico's Federal Tax Court (TFJA), many involving complex cross-border payment structures in the energy sector. My master's degree in oil & gas law gives me the technical fluency to understand what a bareboat charter, FPSO operations agreement, or jack-up drilling contract actually says — and how Mexican tax law should, and should not, apply to those payments.
I work with a small number of clients at a time to ensure each matter receives the strategic attention it deserves.
A technical guide for foreign operators and service providers working in Mexico's oil & gas sector. Covers the legal framework, treaty analysis, contract-specific issues, and recovery process.
4 required fields · all inquiries are confidential
If your company operates in Mexico's offshore or onshore oil & gas sector, the fastest way to understand your exposure — and your recovery opportunity — is a direct conversation.
There is no charge, no obligation, and everything discussed is protected by attorney-client privilege. Calls are conducted via Google Meet or Zoom, and I am available across US Eastern, Central (Mexico City), and European time zones.
Prefer to write first?
uriel@uncommonlegal.com