Chihuahua, Chih., 7th June, 2019.

Dear Clients and Friends,

We hereby inform of the possibility of contesting, by means of an indirect amparo trial, the constitutionality of Rule 9.16 of the Miscellaneous Tax Resolutions for 2019, which will come into force on April 30th, 2019.

The aforementioned rule establishes the requirements to apply for a fiscal incentive for diesel or biodiesel and their mixtures for general machinery. Nevertheless, the requirements for the application for said fiscal incentive were amended for the fiscal year of 2019; thus, the herein informed rule currently establishes new requirements, which may exclude people that previously could have applied for said fiscal incentive.

As a result of the legal analysis made by our firm, we consider that there are several legal flaws that may cause the unconstitutionality of said amendments, thus the claim herein proposed has great possibilities of a favorable resolution.

It is important to note, that the applicable term for the filing of said claim ends in June 11th, 2019.

If the case may be that it is in your interest to file said amparo trial, we will send you a broader document detailing the corresponding procedure, as well as the necessary documentation and the schedules for the corresponding defense.

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.