Chihuahua, Chih., January 21, 2021.
Dear Clients and friends,
We hereby inform you that on January 13th, 2021, the amendment of several provisions regarding the Guidelines that regulate the exercise of the Taxpayer’s Defense Attorney’s Office authorities regarding Conclusive Agreements was published in the Federal Official Gazette.
First, amendments were made to the Federal Tax Code regarding the term in which the herein procedure may be requested by taxpayers seeking a conclusive agreement before the Taxpayer’s Defense Attorney’s Office, that is within the following 20 days after the Final Act, Observations Notice or Electronic Provisional Resolution is issued, pursuant to the type of audit carried out on the taxpayer.
Likewise, the application for a conclusive agreement shall be filed in writing or electronically by the interested party, which shall comply with the requirements foreseen in article 99 of said Guidelines; otherwise, a requirement shall be issued, so that within 5 days following the date on which the notification thereof becomes effective, the taxpayer may correct or complete the application with the omitted requirements, in the understanding that, if the taxpayer fails to comply, the request will not be verified.
Furthermore, pursuant Article 104 of the Guidelines, the Taxpayer Defense Attorney’s Office must ensure at all times that, in its response writ of the corresponding Concluding Agreement, the authority does not change, in the taxpayer’s prejudice, the facts or detected omissions during the course of its verification authorities, otherwise, a serious violation of the taxpayer’s rights will occur.
For further information on this matter, please do not hesitate to contact Mr. Sergio Humberto Salas Medrano, Partner of the Fiscal and Administrative Area, at ssalas@iclmx.com.
Lic. Sergio H. Salas Medrano.
Inintegrum Corporación Legal, S.C.
