ARTICLE 37: NEGATIVE FICTA

The instances or requests made to the tax authorities must be resolved within three months; After this period has elapsed without notification of the resolution, the interested party may consider that the authority resolved negatively and bring the means of defense at any time after said period, until the resolution is issued, or wait for it to be issued.

The period to resolve the inquiries referred to in article 34-A will be eight months. (CFF: Art. 34A)

When the promoter is required to meet the omitted requirements or provide the necessary elements to resolve, the term will begin to run since the requirement has been met.