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.
Download Free Whitepaper →Marine & Offshore Oil Services · Mexico Tax Recovery
¿Why UnCommon Legal?
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. The recovery window is open, but not permanently.
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.
This is a narrow specialty — combining Mexican tax litigation expertise with deep familiarity of oil & gas contract structures. Bareboat charter, FPSO operations agreement, jack-up drilling contract: we understand the technical fluency needed to argue how Mexican tax law should, and should not, apply.
Track record and framework
The Problem
Foreign companies routinely overpay income tax due to misclassification of contract payments and incorrect application of bilateral tax treaties. Three recurring failure modes account for most of the excess withholding.
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 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.
Recovery Process
We review your contracts, historical payments and withholding records to quantify 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 counsel has 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. Our incentives are identical to yours.
Counsel
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. Mexico City · New York (relocating October 2026).
Free Resource
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.
Free Consultation
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 counsel is available across US Eastern, Central (Mexico City), and European time zones.
Prefer to write first? uriel@uncommonlegal.com
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