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Reform Initiative - Guarantee of the Tax Liability
24 MAR 26   |   LEGAL UPDATES

Amendment to Article 141 of the Federal Tax Code

As of January 1, 2026, the “Decree Amending, Adding and Repealing Various Provisions of the Federal Tax Code” entered into force, whereby, among the most significant amendments, is the one to Article 141 regarding the guarantee of actual and potential tax liabilities. This amendment established a mandatory order of priority for guaranteeing such liabilities, providing that, as a general rule, a taxpayer’s tax liabilities must be guaranteed primarily through a deposit certificate, up to the maximum limit of the taxpayer’s financial capacity.



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