First Majestic v. Mexico (I) First Majestic Silver Corp. v. United Mexican States (I) (ICSID Case No. ARB/21/14)
Ownership of Primero Empresa Minera, S.A. de C.V. (“Primero”), a local subsidiary which owns and operates several silver and gold mines in Mexico.
Claims arising out of the national tax authority’s actions to secure amounts allegedly owned by the claimant’s local subsidiary Primero pursuant to tax reassessments as well as the tax authority’s rejection of the claimant’s requests for the initiation of dispute resolution procedures under double taxation treaties. According to the claimant, the tax authority unlawfully opted to ignore advance pricing agreements it had signed with Primero related to the company’s silver sales.
Primary: B - Mining and quarrying
7 - Mining of metal ores
ICSID (International Centre for Settlement of Investment Disputes)
ICSID (International Centre for Settlement of Investment Disputes)
Sacerdoti, G.
Alexandrov, S. A.
Derains, Y.
500.00 mln USD
Data not available
National treatment

Most-favoured nation treatment

Fair and equitable treatment/Minimum standard of treatment, including denial of justice claims

Indirect expropriation

Transfer of funds