ARTICLE 36: MODIFICATION OF ADMINISTRATIVE RESOLUTIONS

Administrative resolutions of an individual favorable to a particular may only be modified by the Federal Tax Court (Tribunal Fiscal de la Federación) by trial initiated by the tax authorities.

When the Secretary of Finance and Public Credit (Secretaría de Hacienda y Crédito Público) modifies the administrative resolutions of general rules, these modifications will not include the effects produced prior to the new resolution.

The tax authorities may, at its discretion, review the administrative resolutions of an individual not favorable to an particular issued by their subordinates hierarchically and, in the event that it is duly demonstrated that they were issued in contravention of the tax provisions, they may, only once, modify or revoke them for the benefit of the taxpayer, as long as the taxpayers have not filed means of defense and the terms for submitting them have elapsed, and without having prescribed the tax credit.

The aforementioned paragraph shall not constitute as a petition and the resolutions issued by the Secretary of Finance and Public Credit (Secretaría de Hacienda y Crédito Público) in this regard may not be challenged by taxpayers.