The Fiscal Resolution of 2015 states that people who report income above 4 million pesos shall send the trial balance and chart of accounts no later than March 3, 2015, when it is considered in terms of the Law of Protection the first act of application of the Section IV, of Article 28 of the Federal Tax Code (CFF).

Currently there are pending of resolution a multiplicity of cases brought last year on this assumption, that is, a lot of protection actions were raised against that standard by considering that the taxpayer is in a state of permanent tax supervision, which causes a state of legal defenselessness.

Furthermore, it was considered that the guarantees relating to data protection are violated, because taxpayer accounting data contains sensitive information about their financial situation, so the obligation to submit monthly accounting reports exposes the company without any warrant duly grounded.

Finally, it’s worth noting that according to the principle of relativity of judgments, under which the grant of a protector ruling only benefits those who requested it, to date, statements pursuant tax protection have no effects of general declaration.