📢 Supreme Court Upholds the Constitutionality of the 20-Day Deadline for Filing a Conclusive Agreement Request ⚖️📅

he First Chamber of the Supreme Court of Justice of the Nation (SCJN) has confirmed the constitutionality of Article 69-C of the Federal Tax Code, which establishes a 20-day deadline for taxpayers to request a conclusive agreement after the tax authority has assessed facts or omissions.

📌 Key Takeaways from the SCJN Ruling

📍 The rule ensures legal certainty without obstructing tax audits.
📍 Does not restrict access to alternative dispute resolution mechanisms.
📍 Balances taxpayers' rights with effective tax enforcement.

📌 The SCJN ruled that the provision is rational, appropriate, and proportional, affirming the legislature's discretion in tax matters, provided the regulation meets minimum suitability and proportionality standards, which were deemed to be met in this case.

📢 Impact of the Ruling on Tax Law

🔹 Strengthens legal certainty in tax audit procedures.
🔹 Prevents unnecessary delays in conclusive agreements.
🔹 Ensures access to dispute resolution mechanisms without undermining the state's auditing functions.

📌 This ruling confirms that the 20-day deadline for requesting a conclusive agreement is a valid and constitutional mechanism to streamline tax procedures in Mexico.

📢 Conclusion

📌 The SCJN upholds the constitutionality of the 20-day deadline for conclusive agreements in tax matters.
📌 This measure ensures a balance between taxpayers' rights and efficient tax audits.

🚨 What do you think about this SCJN decision? Share your thoughts in the comments.

📚 Official Sources

📌 Full SCJN Ruling: 🔗 SCJN - Press Releases
📌 Federal Tax Code: 🔗 Consult Here