Through the publication on the tax authority’s webpage, on May 29, 2020, of the
first preliminary draft of the Second Miscellaneous Tax Resolution applicable for
2020, important changes to rule 2.2.1 (password generated by taxpayers) were
made.

It should be remembered that the password replaced the autograph signature,
producing the same effects that the laws granted to the autograph signature and
having equal probative value.

Through the draft published, it was established that the password would be valid
for 4 years, following the day the password was generated or on the date the last
update was made. The password must be renewed through any of the means
designated by the tax authority.

We believe that the tax authority wants to standardize the terms established for the
e-signature and the password, for them to be valid for 4 years.

However, this rule does not establish the moment from when the 4 years should be
computed, since the previous password had no expiration date. Therefore, what
will happen to passwords over 4 years old? Will it be necessary to renew them to
start computing the new term?

This proposal would affect both legal entities and individuals, so we will be
attentive to inform you if it is published in the Official Federal Gazette, to carry out
the respective actions and avoid problems regarding the submitting of statements
and procedures in general.

We remain at your service for any questions or clarification in this regard.