Chihuahua, Chih., January 17th, 2019.

Dear Clients and Friends,

We hereby inform you of the possibility of contesting the Federal Income Law for the Fiscal Year 2019, specifically its article 25 section VI, through an Indirect Amparo trial; with the intention of claiming the possibility of offsetting different kinds of taxes, as it was previously performed.

Last December 28th 2018, the Federal Income Law for the Fiscal Year 2019 was published on the Federal Official Gazette, which establishes several limitations for all of the taxpayers, which will greatly impact the operations of the Companies.

One of the most relevant amendments amongst the herein information is the prohibition to offset taxes of a different nature, meaning that as of the fiscal year 2019, taxpayers will only be able to offset their credit balances against their negative balances, when both are related to the same tax, which will highly impact in the operation of the Companies.

It is important to note, that the deadline to file the suit for said trial ends on February 12th 2019.

For more information regarding this topic, please do not hesitate to contact Mr. Sergio Humberto Salas Medrano, Partner of the Fiscal and Administrative Area, at his email ssalas@iclmx.com, as well as Mrs. Ana Gabriela Moreno Luna, at her email amoreno@iclmx.com, and Mr. Fernando Antonio Borunda Bustamante at his email fborunda@iclmx.com.

Mr. Sergio H. Salas Medrano.

Inintegrum Corporación Legal, S.C.