Agreement on the Territorial Jurisdiction of the Administrative Units of PRODECON in Matters of Conclusive Agreements

Agreement on the Territorial Jurisdiction of the Administrative Units of PRODECON in Matters of Conclusive Agreements

By means of Operating Agreement A/2024/CTN/AO, the Office of the Taxpayer Defense Attorney (“PRODECON”) established that, in view of the workloads of that agency’s Administrative Units, the processing of Conclusive Agreements will be handled according to the following criteria:

I. Conclusive agreements arising from audit actions by Decentralized Tax Audit Administrations and Central Audit Administrations Each PRODECON delegation will hear the conclusive agreements arising from actions issued by the Administrations according to the Federative Entity in which such authorities are located (except for the Puebla delegation, which will also handle the agreements arising from actions issued by the Decentralized Administration of Tlaxcala). On the other hand, PRODECON’s Central Office will handle those agreements arising from actions issued by the Decentralized Administrations of the Federal District, as well as those issued by the Central Administrations (Large Taxpayers, Corporate Groups, Financial Sector, Hydrocarbons, Transfer Pricing, Strategic, International, and Hydrocarbons Verification). II. Conclusive agreements arising from audit actions by Coordinated Authorities, IMSS, and INFONAVIT Each PRODECON delegation will hear those conclusive agreements according to the Federative Entity to which the local Coordinated Authority, sub-delegation, or Audit Coordination Office belongs. III. Conclusive agreements arising from audit actions by Central and Decentralized Foreign Trade Audit Administrations Unlike the previous cases, for conclusive agreements originating from actions issued by the Foreign Trade Administrations, the taxpayer’s tax domicile must be considered. On the other hand, the Agreement establishes that if a PRODECON Administrative Unit receives a request for a Conclusive Agreement that does not fall within its jurisdiction, it has the obligation to forward the documentation by email to the corresponding Administrative Unit within a maximum period of 2 hours. Likewise, if the Administrative Unit receives the documentation through its Records Office (Oficialía de Partes), it must forward it no later than the following business day. Once the request for a Conclusive Agreement is received by the competent Administrative Unit, the 2-hour period it has to send the suspension notice begins to run. At Von Wobeser y Sierra, we have a team of experts in tax litigation matters who have handled hundreds of Conclusive Agreements, achieving excellent results for our clients and avoiding lengthy, uncertain, and very costly litigation. For contact, please reach out to: Alejandro Torres, Partner:+52 (55) 5258-1072 | ajtorres@vwys.com.mx Luis Enrique Torres, Counsel:+52 (55) 5258-1023 | ltorres@vwys.com.mx

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