One thing that makes the Mexican tax system different from many other tax systems in the world is that its legal provisions are constantly modified.
At least once a year, the Mexican Congress enacts a bill amending relevant tax statutes. In order to counterbalance the periodic changes to tax provisions, the Mexican Fiscal Code of the Federation (“FCF”) allows taxpayers to request tax rulings from the Mexican Treasury. Until December 31, 2006, tax rulings were always binding for the Mexican Treasury, and were challengeable by the taxpayers.
However, effective as of January 1, 2007, two important modifications to the provision that regulates tax rulings were enacted: (i) tax rulings will be binding for the Mexican Treasury only if certain requirements are met; and (ii) taxpayers should not be entitled to challenge tax rulings.