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Mexico: “Certain date” on documents, tax law implications

Mexico: “Certain date” on documents, tax law

The Second Chamber of the Supreme Court of Justice of the Nation (Segunda Sala de la Suprema Corte de Justicia de la Nación) issued a judgment clarifying the term “certain date” for purposes of documents presented by taxpayers in satisfying certain tax obligations.


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The high court’s Second Chamber established that a “certain date” (fecha cierta) on the subject documents would be: (1) when the documents are registered with the public property registry (Registro Público de la Propiedad); (2) as of the date when the documents are presented to a notary public; or (3) as of the date of death of a signatory to the documents.

While the “certain date” requirement is not enforceable under current tax legislation, this condition could be critical in relation to the probative value of documents that are intended to be presented to the tax authorities.

Read a December 2019 report (Spanish) prepared by the KPMG member firm in Mexico

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