Wealth Protection
In an uncertain legal and economic environment, we design strategies to shield our clients' wealth before enforcement arrives.
Tax · Administrative · Constitutional Law
The right strategy always wins. With this definition of success, we never lose.
Our commitment
Tax law practiced with judgment and passion.
Pagaza Abogados was born of a conviction: to practice tax law with technical excellence, human attention, and a practical focus that delivers efficient, dependable legal solutions to protect our clients' wealth.
Technical excellence
Human attention
Practical focus
We are lawyers specialized in public law as our single field of practice, so we can bring our full attention to the most complex, highest-risk matters.
Services
Prevent, manage, resolve.
We help prevent, manage, and resolve highly complex tax and administrative disputes.
We handle audits, tax examination proceedings, and litigation before tax and administrative authorities. Enforcement today runs on more technology and less margin: the strategy must protect the client's wealth without halting the business.
How we work
Three pillars, in order of priority.
Our practice rests on three sequential pillars: prevent before correcting, negotiate before litigating, and litigation when there is no other way out.
Advisory & Transactional
We analyze and design the tax structure of each transaction: optimize the outcome, contain legal risk, and sustain compliance.
Tax & Public Litigation
Faced with an act of authority we prioritize technical negotiation as the route to resolution, with litigation ready for when it is needed.
Direct guidance and representation before authorities at all three levels of government: federal, state, and municipal.
Capabilities
Legal solutions for highly complex tax and regulatory matters.
We prevent, manage, and resolve the tax and administrative disputes that affect the wealth and operations of companies, investors, and corporate groups.
Audits and tax examination proceedings
We represent our clients through audits and review proceedings initiated by tax and administrative authorities, defining strategies that reduce risk, preserve operational continuity, and provide legal certainty.
Tax disputes
We advise and represent our clients in disputes involving federal and local taxes, refunds, tax assessments, VAT and income tax (ISR) discrepancies, social security contributions, and other tax obligations.
Tax and constitutional litigation
We handle administrative appeals, contentious proceedings, and Amparo (constitutional-relief proceeding) actions to protect taxpayers' rights against acts of authority, always on a technically sound legal strategy.
Tax negotiation and regularization
We design negotiation strategies before tax and administrative authorities through institutional mechanisms that reduce contingencies, regularize legal positions, and give our clients certainty.
Tax planning
We analyze domestic and cross-border transactions to structure tax-efficient alternatives, identify risks, and ensure compliance with tax obligations within the applicable legal framework.
Foreign trade and international taxation
We advise on cross-border transactions in foreign trade, tax treaties, VAT on cross-border operations, imports, exports, and other tax aspects of international business.
Social security
We represent companies in proceedings involving social security contributions, audits by the Mexican Social Security Institute (IMSS), the calculation of the contribution base salary, risk classification, and other employer obligations.
Regulatory compliance
We advise companies on meeting regulatory obligations and on responding to specialized administrative proceedings, implementing preventive strategies aimed at reducing legal and financial risk.
Wealth protection
We design legal structures to organize and protect corporate and family wealth, including corporate reorganizations, trusts, and other legal mechanisms with tax implications.
Strategic advisory
We issue specialized legal opinions on highly complex transactions, providing certainty in decision-making through a comprehensive analysis of the tax, administrative, and constitutional framework.
Anti-Money Laundering (AML)
We advise companies on their anti-money-laundering obligations, implementing compliance programs and representing our clients in verification proceedings and in their defense before the competent authorities.
Experience & industries
Proven experience across twelve industries.
Experience is proven with cases. A selection of real matters, by sector.
Automotive
Advisory to OEMs and their supply chains on tax and social-security audits, local litigation, and international operations under the USMCA.
Specialized-services (REPSE) compliance to avoid critical contingencies before the IMSS and the tax authorities.
Substantial reductions in local-tax disputes through litigation and technical negotiation.
Constitutional defense (Amparo) against USMCA proceedings and recovery of VAT refund balances on exported technical assistance.
Manufacturing
Representation in complex cross-border tax disputes, with emphasis on VAT in international trade.
Complete elimination of a multi-million-peso contingency over an alleged failure to withhold VAT from foreign residents, averting a double-taxation impact.
A final favorable ruling at the administrative level on a criterion still under review by the Supreme Court (SCJN), granting the client anticipated legal certainty.
Real Estate & Construction
Comprehensive tax planning, social-security audits, and estate-portfolio structuring for developers and construction firms.
Accurate determination of accruable income and application of the ISR estimated-cost deduction for construction firms.
Defense in IMSS construction audits, preventing the presumptive assessment of employer–employee contributions.
Family trusts to isolate high-value real-estate assets and recovery of overpaid property-transfer taxes.
$12M
in penalties reduced — AML audit
A $12,000,000 MXN reduction in penalties for a client, obtained through our intervention in an anti-money-laundering audit.
Textile
Tax planning for contracting-market scenarios and high-specialization customs defense.
Representation of a group distributing international brands: customs authorities sought to raise the import tax base by adding royalties paid to foreign residents.
Recognition and tax deductibility of inventory losses driven by Asian competition and sector volatility.
Retail & Wholesale
Voluntary tax correction, executive-level accounting restructurings, and protection of family assets.
A structural restructuring and technical reclassification of operations that restored financial viability during a critical high-demand cycle.
Asset-protection trusts to safeguard strategic fixed and intangible assets of family businesses against the tax authority's audit powers.
Education
Estate restructurings to isolate school infrastructure from operational risk, and tax regularization on VAT matters.
Isolation of real-estate assets and school infrastructure (strategic assets) from the risks inherent to the education service.
Tax cleanup applying Federal Circuit Court criteria on VAT for educational services and related activities.
Defense of politically exposed persons
High-level defense for individuals holding public office or of political relevance against investigations by public authorities.
Administrative-liability proceedings before internal control bodies and audits by the Federal Superior Audit Office (ASF).
Unfreezing of bank accounts and immediate constitutional wealth defense against extreme precautionary measures.
Supplements & Consumer Goods
Wealth and intellectual-property protection for fast-moving consumer-goods corporations.
Structuring for the ownership, exploitation, and licensing of high-value intangibles (brands and formulas).
Mitigation of regulatory risk before health authorities and of contingencies from intangible-asset transfers.
Pharmaceutical
Representation against complex health regulations and SAT audits.
Express resolution of Digital Seal Certificate (CSD) restrictions, restoring invoicing in minimal timeframes.
Coordination and defense of electronic reviews, on-site audits, and desk reviews by the federal tax authority.
Energy
Tax disputes arising from infrastructure projects and analysis of the tax incentives available to strategic investments.
Advisory to energy-sector companies on tax disputes involving infrastructure projects, pre-operating activities, and tax recovery.
Analysis of the tax incentives applicable to strategic investments in the sector.
Financial Services
Representation of financial institutions and corporate groups in highly complex tax and administrative disputes.
Representation of banks, financial companies, and corporate groups in highly complex tax and administrative disputes.
Defense in sanctioning proceedings, supervisory actions, and appeals before regulatory and tax authorities.
Social Impact
High-impact pro-bono practice to protect fundamental rights against abuses by the State.
Restoration of pensions and medical services unlawfully suspended by the IMSS or ISSSTE, with retroactive payment of benefits.
Compensation for State financial liability and defense of merchants against arbitrary closures and the unlawful seizure of goods.
Alliances & coverage
A tax core, a 360° network.
We never dilute our specialty. When a matter demands it, we connect with a select network of experts by practice area and with correspondents inside and outside Mexico.
- Accounting & finance
- Individual & collective labor
- Corporate & M&A
- Life sciences & advertising
- Criminal
- Tax crime
- Regulatory & compliance
- Transfer pricing & appraisals
- Civil & commercial
- Finance & capital markets
Our offices
We have two offices in Mexico.
- Mexico City
- Prado Sur 525, Lomas de Chapultepec, Miguel Hidalgo, 11000, Mexico City
- Ciudad Juárez
- Punto Alpha Torre de Negocios, Campos Elíseos 1961 – 8C, Ciudad Juárez, Chihuahua 32472
Our team
The people handling your matter, from day one.
At a boutique the partner does not supervise your matter from a distance: they design and defend it, backed by a team focused on tax and administrative law.
Alfonso Pagaza
Founding Partner
Alfonso holds a law degree with honors from Escuela Libre de Derecho and a specialization in Tax Law from the same institution. He advises and represents companies, investors, and business groups in complex domestic and international matters. His practice spans tax controversy and advisory, strategic litigation, social security, State liability, and regulatory and anti–money laundering (AML) proceedings, as well as foreign trade and international taxation. His approach combines technical–tax analysis with legal strategies designed to protect his clients' assets and operations.
Jorge Díaz-Galindo
Associate
Jorge holds a law degree and a graduate degree in Tax Law, both from Universidad de las Américas Puebla (UDLAP). He specializes in tax and administrative litigation, with command of social security matters for both companies and individuals. His practice is marked by a client-centered approach to protecting taxpayers' rights before administrative and judicial authorities. He also has experience in tax advisory, delivering tailored solutions that are efficient, strategic, and secure for his clients' interests.
Dafne Sánchez
Associate
Dafne holds a law degree from the School of Law of the Universidad Nacional Autónoma de México (UNAM). She specializes in Tax Law and regulatory compliance, with particular emphasis on anti–money laundering. Her practice covers audit and enforcement proceedings, as well as the design and review of compliance programs for companies subject to regulatory obligations.
María José Núñez
Law Clerk
María José is an eighth-semester law student at Universidad Anáhuac México, Campus Norte, currently working as a law clerk in the tax and administrative areas with a litigation focus. Her work supports the defense of taxpayers' interests before the tax authorities. She has experience preparing and following amparo proceedings, administrative appeals (recursos de revocación), and matters before administrative and tax courts.
Patricio Duarte
Law Clerk
Patricio is a law student at Escuela Libre de Derecho, currently working as a law clerk in the tax and administrative areas. His practice focuses on tax controversy and administrative proceedings, taking part in the defense of taxpayers against audits, tax assessments, and enforcement proceedings before administrative authorities.
David Reyes-Jains
Law Clerk
David is a law student at UNAM, Campus Aragón, focusing on tax and administrative matters. His practice centers on tax advisory and conclusive agreement (acuerdo conclusivo) proceedings, contributing to the analysis of tax contingencies and to audit proceedings before the tax authorities.
Contact
Schedule a consultation.
Tell us about your situation. The first conversation is confidential and without obligation.
Or contact us directly
Pagaza Abogados Tributarios
(55) 78-91-88-65a@pagaza.mxMexico CityPrado Sur 525, Lomas de Chapultepec, Miguel Hidalgo, 11000, Mexico City
Ciudad JuárezPunto Alpha Torre de Negocios, Campos Elíseos 1961 – 8C, Ciudad Juárez, Chihuahua 32472