ARTICLE 67: TERM IN WHICH THE FACULTIES ARE EXTINGUISHED TO DETERMINE OMITTED CONTRIBUTIONS OR EXPLOITATIONS AND ITS ACCESSORIES, AS WELL AS TO IMPOSE SANCTIONS

The faculties of the tax authorities to determine the omitted contributions or exploitations and its accessories, as well as to impose sanctions for infractions of the tax provisions, are extinguished within five years from the day following that in which:

The period referred to in this article will be ten years, when the taxpayer has not submitted their request in the Federal Taxpayer Registration, does not keep their accounting records or do not keep it during the period established by this code, as well as for the periods in which they do not present any statement of the exercise, being obliged to present them, or is not presented in the income taxes declaration the information regarding the value added tax or the special tax on production and services is requested in said declaration; In the latter case, the ten-year term shall be counted from the day following that on which the aforementioned declaration should have been submitted. In cases where the taxpayer subsequently spontaneously submits the omitted declaration and when it is not required, the period will be five years, without in any case this period of five years, added to the time elapsed between the date on the that the omitted declaration must have been submitted and the date on which it was submitted spontaneously, exceeds ten years. For the purposes of this article, the statements of the year do not include those of provisional payments.

In the cases of responsibility for solidarity referred to in article 26 sections III, X and XVII of this Code (CFF: Art. 26), the period will be five years after the fiscal interest guarantee is insufficient.

The period indicated in this article is not subject to interruption and will only be suspended when they exercises the faculties of verification of the tax authorities referred to in sections II, III, IV and IX of article 42 of this Code (CFF: Art. 42); when an administrative appeal or trial is brought; or when the tax authorities cannot initiate the exercise of their faculties of verification by virtue of the taxpayer having vacated their fiscal address (CFF: Art. 10) without having submitted the corresponding notice change or incorrectly indicated its tax address. In these last two cases, the calculation of the expiration period will be restarted from the date on which the taxpayer is located. Likewise, the period referred to in this article will be suspended in cases of strike, from which work is temporarily suspended and until the end of the strike and in the death of the taxpayer, until the legal representative of the succession. Likewise, the period referred to in this article will be suspended, with respect to the company that, having the status of an integrator, calculates the fiscal result integrated in the terms of the provisions of the Law on Income Tax (Ley del Impuesto sobre la Renta), when the tax authorities exercise their faculties of verification with respect to any of the companies that have the character of integrated of said integrating company.

The expiration period that is suspended on the occasion of the exercise of the faculties of verification above-mentioned, begins with the notification of its exercise and ends when the final resolution is notified by the tax authority or when the deadline ends established by Article 50 of this Code (CFF: Art. 50) to issue it. If the resolution is not issued, it will be understood that there was no suspension.

In any case, the expiration period that is suspended on the occasion of the exercise of the faculties of verification, added with the period for which said expiration is not suspended, may not exceed ten years. In the case of home visits, review of the accounting in the offices of the authorities themselves or of the review of dictums, the expiration period that is suspended due to the exercise of the faculties of verification, added with the period for which it is not suspends said expiration, may not exceed six years with six months or seven years, as appropriate.

The faculties of the tax authorities to investigate facts constituting crimes in fiscal matters, shall not be extinguished according to this article.

Taxpayers, after the deadlines referred to in this article, may request that the faculties to declare that the tax authorities have been extinguished.

The terms established in this article will not affect the implementation of the agreements reached as a result of the dispute resolution procedures provided for in the treaties to avoid double taxation of which Mexico is a part of.