ARTICLE 36 BIS: VALIDITY OF AN INDIVIDUAL OR GENERAL RESOLUTIONS

The administrative resolutions of an individual character or directed to groups, dictated in the matter of taxes that grant an authorization or that, being favorable to individuals, determine a fiscal regime, will have their effects in the fiscal year of the taxpayer in which they are granted or in the immediate prior year, when the resolution had been requested, and it is granted within three months of its closing. (CFF: Art. 18A)

At the end of the fiscal year for which a resolution has been issued, as indicated in the preceding paragraph, the interested parties may submit the circumstances of the case to the competent tax authority to issue the corresponding resolution.

This provision shall not apply to authorizations related to extensions for payment in partial payments, acceptance of guarantees of fiscal interest, which are required by law for the deduction in investments in fixed assets and referred to in article 59 of the Law on Income Tax (Ley del Impuesto sobre la Renta).