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Mexican Supreme Court of Justice And Double Taxation in Mexico (Indirect Amparo’s Review 32/2006)

Table of Contents

A) Summary of the Judgment

This judgment was issued from an indirect amparo proceeding against general norms that an individual filed challenging several legal provisions that created the schedular tax in the state of Guanajuato, México. The core of his complaint was that this tax only applies to individuals but not legal entities or companies.

In the amparo mentioned above, the complainant alleged that the fact that a fixed rate of 2% was applied to the taxed income based on: A) a professional service, B) the leasing of real estate located in the state, and C) carrying out business activities, violated the principle of tax proportionality because a progressive rate had not been established to measure the true economic capacity of the taxpayer.

On the other hand, also prominently, the complainant alleged that the schedular tax violated the principle of tax equity by excluding legal entities from its application without, apparently, lawmakers providing an objective and reasonable justification. Hence, it requested the removal of the tax from its legal sphere.

The judge who had to hear the matter denied the protection of federal justice because he considered that the challenged regulations did not violate the principle of tax proportionality, while he failed to rule on the arguments related to the violation of the principle of equity tax.

When the matter reached the Mexican Supreme Court of Justice, it declared unfounded the arguments regarding evidencing a violation of the principle of tax proportionality because, on the one hand, it stated that this principle is also respected when fixed rates are established, and lawmakers don’t need to establish progressive rates. On the other hand, because the complainant did not demonstrate that the accumulation of the schedular tax and the income tax was ruinous to consider the first tax—and new tax— as unconstitutional. Especially if there was no express prohibition on double taxation in the Constitution of the United Mexican States.

Regarding the allegation of the principle of tax equity, the Mexican Supreme Court of Justice rejected the arguments because, in its opinion, the fact that the state of Guanajuato celebrated an Agreement of Adherence to the National Fiscal Coordination System with the Federation and pursuant to the Value Added Tax Law, only individuals were allowed to be taxed on income that was also taxed for legal entities in federal taxes. Therefore, an objective and reasonable justification existed for the schedular tax to fall only on individuals, not legal entities.

Finally, to understand this judgment better, I recommend you check my entry called ‘Constitutional Principles of Taxes in Mexico’ because there I explained the principles of equality and proportionality of taxes in Mexico.

B) Source’s Case and Judicial Criteria

The judgment summarized deals with the unconstitutionality of double taxation in Mexico and has as its origin the ruling issued in the Indirect Amparo’s Review 32/2006  crafted now by Justice (ministro) Juan N. Silva Meza, which was held on June 28, 2006. Judgment that eventually gave rise to the following judicial criterion: SCHEDULAR TAX ON THE INCOME OF INDIVIDUALS. THE FACT THAT DOUBLE TAXATION FALLS ON THE SAME OBJECT DOES NOT MAKE IT UNCONSTITUTIONAL[1].

C) Responsible Authorities

As responsible authorities, the complainant stated:

I.- Congress of the Union; II.- Mexico’s president; III.- Secretary of the Interior; IV.- Secretary of Finance and Public Credit; V.- Director of the Official Gazette of the Federation; VI.- Congress of the State of Guanajuato; VII.- Governor of the State of Guanajuato; VIII.- Secretary of the Government of the State of Guanajuato; IX.- Secretary of Finance and Administration of the State of Guanajuato; X.- Local Collection Administrator in Celaya; XI.- Local Head of Municipal Revenue and XII.- Director of the Official Newspaper of the State of Guanajuato.

D) Authorities Acts Challenged

I.- The decree published in the Official Newspaper of the State of Guanajuato in December twenty-seven two thousand four, which establishes the Finance Law for the State of Guanajuato, specifically the complainant claimed articles 9[2], 14[3], 16[4], 17[5], and 18[6]. II.- Also, the decree establishing the Income Law of the State of Guanajuato for the tax season year two thousand five, published in the Official State Newspaper on December twenty-seven two thousand four, specifically article 1, section I, Section B, number 1, and article 4, Section B), number 1 and finally III.- Decree by which various provisions of the Value Added Tax Law are established, reformed, added, and repealed, published in the Journal Official of the Federation on January 1, 2015, claims explicitly article 43[7].

E) Procedure before the Sixth District Court of the Sixteenth Federal Circuit

I.- Background

1) On March 10, 2005, the complainant, in his own right, filed an Indirect Amparo Proceeding against the claimed acts of the authorities already mentioned above.

2) On the other hand, the complainant indicated in his amparo that such claimed acts violated articles 14, 16, 31, section IV, 73, sections VI, VII, XXIX-A, 74, 117, 124, 128 and 133 of the Constitution Politics of the United Mexican States.

3) By order dated March 14, 2005, the Sixth District Court of the Sixteenth Circuit admitted the Indirect Amparo Proceeding under the number 369/2005.

4) Following the procedures contemplated in the law, on May 16, 2005, the Sixth District Court issued a final ruling in which he dismissed the case in part and denied federal protection to the complainant.

II.- Reasoning

1) The dismissal derived from the alleged inapplicability of the claimed acts of the Secretary of Finance and Administration, the Local Head of Revenue of the Municipality, and the Local Administrator of Tax Collection. Negative, which was not refuted by the complainant.

2) Regarding the denial of the federal protection, the judge held that the articles claim as unconstitutional did not violate the principle of tax proportionality since the 2% rate that was used to determine the amount of the tax was applied to the entire income that was obtained for the provision of professional services or for the granting of the use or enjoyment of real estate, or for carrying out business activities. Therefore, the amount to be paid would vary depending on the amount of income obtained from the development of the aforementioned activities.

3) Likewise, the district judge held that the contested articles did not violate the principles of tax proportionality and equity because article 43 of the Value Added Tax Law recognized the possibility for federal entities to establish schedular taxes on individuals’ income. Then, the creation of a schedular tax did not constitute a breach of the Agreement of Adherence to the National Fiscal Coordination System.

4) In any case, the district judge categorically argued that in any case, double taxation is not expressly prohibited in the Political Constitution of the United Mexican States.

5) Finally, the judge also held that article 43 of the Value Added Tax Law also did not violate the principles of legality and legal certainty since the creation of the schedular tax by the state legislature found support in article 124 of the Political Constitution of the United Mexican States, as well as in the Agreement of Adherence to the National Fiscal Coordination System that the legislature celebrated with the Ministry of Finance and Public Credit.

F) Procedure before the Third Collegiate Court of the Sixteenth Circuit

I.- Background

1) Dissatisfied with the judgment issued by the Sixth Judge of the Sixteenth Circuit, the complainant, on July 18, 2005, filed a legal remedy called ‘review’ against said resolution.

2) indirect amparo’s review that was heard by the Third Collegiate Court of the Sixteenth Circuit on August 31, 2005, admitted under file number 282/2005.

3) Once the indirect amparo’s Review was analyzed, the Third Collegiate Court of the Sixteenth Circuit, in a session dated December 8, 2005, reserved its jurisdiction to the Mexican Supreme Court of Justice for resolving the case on merits and sent the file to our highest court.

G) Complainant’s Arguments

Against the judgment issued by the Sixth District Court of the Sixteenth Federal Circuit, the complainant argued the following:

1) In the first argument, the complainant argued that establishing 2% as a schedular tax, without any distinction, violated the principle of tax proportionality.

2) That such violation was since the lawmakers did not consider the true contributory capacity of the taxpayer, nor the fact that the Federal Income Tax Law already taxed income from professional services. Argument that the district court had not addressed it in its judgment.

3) On the other hand, he also argued that the district court failed to address the issue raised regarding the violation of the principle of tax equity. Therefore, it was necessary to restudy this argument on merits.

4) The Previous violation rested on the district judge’s omission to rule on whether there was an objective justification for the lawmakers of the state of Guanajuato to tax the income of individuals, but not legal entities, with the schedular tax.

H) Decision of the Mexican Supreme Court of Justice

I.- Violation of the Principle of Tax Proportionality

1) The Mexican Supreme Court of Justice declared the argument presented concerning the principle of tax proportionality as unfounded, reasoning that the unfoundedness derived from the fact that, contrary to what was stated by the complainant, the district judge had correctly studied the aforementioned principle.

2) To support this,  the court remembered that before, it had held that taxpayers of the tax must contribute to public spending, based on their respective contributory capacity, in such a way that those who obtain high incomes are taxed to a greater extent than those with medium or low incomes, always seeking congruence between the amount of tax to pay and the real capacity to contribute to public spending. The above, as established in the binding criterion: TAX PROPORTIONALITY. THERE MUST EXIST CONGRUENCE BETWEEN THE TAX AND THE TAXING CAPACITY OF THE TAXPAYERS[8].

3) That the conclusion drawn from the previous binding precedent was that what was alleged by the complainant was not correct, in the sense that the quantitative difference is not a true proportionality, since the fact that the tax is collected based on the taxable capacity of each person is what generates that quantitative difference, which in turn responds to the principle of tax proportionality.

4) That the fact that the Finance Law for the State of Guanajuato does not create a progressive rate, but rather a fixed rate of 2% is applied, does not make the schedular tax disproportionate. This was so because although the Supreme Court of Justice itself, in previous cases, had held that the best way to address the economic capacity of the taxpayer was through progressive rates, it is also true that it had specified that these were useful in the case of the taxpayer’s total income. Still, nothing prevented a fixed rate from being applied while taxing a specific manifestation of wealth.

5) Furthermore, the fixed rate also addresses the tax capacity since when applying said rate, those who earned more shall pay more, precisely in proportion to their income. Hence, it was evident that the constitutional defect alleged by the complainant regarding violating the principle of tax proportionality did not exist.

6) Regarding the topic of the double taxation that is generated between the schedular tax for the activities that the Federal Income Tax Law also taxes and that, in the opinion of the complainant, even with the existence of the Fiscal Coordination Law the principle of tax proportionality resulted violated; the Supreme Court of Justice of concluded those arguments were unfounded.

7) To understand why the arguments were unfounded, it was necessary to specify the difference between the taxes’ source and their object. In that sense, the court argued that by source, we should understand those economic activities carried out by taxpayers and taxed by lawmakers’ decisions. In contrast, the object should be understood as the matter on which the tax falls, that is, the event generating the tax liability.

8) In the specific case, from the schedular tax applicable to individuals, they are obliged to pay the aforementioned tax for the income they obtain from providing professional services, granting the use of real estate, or carrying out business activities. Consequently, it was clearly distinguished that the source of the tax is constituted by different activities that the taxpayer eventually carries out, while the object of the tax was the income, performance, or profit taxed by the legislator.

9) Therefore, it was clear that the genus is the source and the species is the object. Hence, two different taxes sometimes affect the various facets that make up a certain economic activity, each of these facets becoming the object of the tax. Thus, double taxation would necessarily fall on the object of the tax to the extent that the source of the tax could be taxed by several taxes simultaneously. What could happen, for example, when production, marketing and consumption were taxed separately, that is, three manifestations of the same activity allow three different objects to be taxed.

10) Conversely, the Mexican Supreme Court of Justice clearly expressed that double taxation itself is not unconstitutional since no legal provision in our constitution bans it. At most, the indirect unconstitutionality would derive from equity and proportionality tax principles. Still, it was not enough to affirm its violation because it was necessary to demonstrate it[9] to conclude that multiple taxation was ruinous and, therefore, exhausted or even extinguished the source of wealth or taxes. A conclusion supported the following jurisprudential criteria issued by our highest court: DOUBLE TAXATION. ITSELF IT IS NOT UNCONSTITUTIONAL[10] and DOUBLE TAXATION. PROOF OF ITS DISPROPORTIONALITY AND INEQUITY[11].

11) Finally, the Mexican Supreme Court of Justice noted that even if the complainant has not proven that the sum of the activity taxed by the Federal Income Tax and the Schedular Tax was ruinous and, therefore, unconstitutional, it was also confirmed that from article 123, section VII of the Income Tax Law in force for the specific case, the percentage of the local tax subject to analysis was deductible against the Federal Income Tax, which clearly illustrated that the sum of both taxes were not ruinous.

II.- Violation of the principle of Tax Equity

1) The Mexican Supreme Court of Justice declared well-founded the issue raised against the Sixth District Court of the Sixteenth District, which failed to study the merits of violating the tax equity principle in the complainant’s first argument in his indirect amparo proceeding. An argument was based on the fact that the schedular tax was inequitable because lawmakers only imposed it on individuals, but not on legal persons, without an objective justification for such differentiation.

2) Consequently, and without the need for jurisdiction referral, the Mexican Supreme Court of Justice would study the argument regarding the violation of the principle of tax equity, which, in the end, was declared unfounded for the reasons I explain below.

3) To justify the unfounded of the argument, first off, the Mexican Supreme Court of Justice and according to its judicial criterion: TAX EQUITY. ITS ELEMENTS[12] and TAX EQUITY. IMPLIES THAT THE RULES DO NOT GIVE DIFFERENT TREATMENT TO ANALOGOUS SITUATIONS OR EQUAL TREATMENT TO PEOPLE WHO ARE IN DIFFERENT SITUATIONS[13] concluded the principle of tax equity translated into equality, before the tax law, of all taxable subjects of a same tax, those who under such conditions should receive identical treatment regarding the hypothesis of accrual, accumulation of taxable income, permitted deductions, payment terms, etc. Only the applicable tax rates may be varied if through this variation it is achieved that taxpayers pay taxes according to their economic capacity to respect the principle of tax proportionality.

4) As far as individuals were concerned, from reading the challenged articles, it was clear that all those who fell under the hypothesis of accrual of the schedular tax would be taxpayers, sufficient reason to arrive at equality in the application of the tax, attentive to the fact that there is universality and generality with respect to the subjects that fall within the assumptions of the law.

5) Moreover, the fact that the legislature of the State of Guanajuato has only considered taxing income from the provision of professional services, the granting of temporary use or enjoyment of real estate, and from the performance of business activities of individuals, without considering legal entities; did not violate the principle of tax equity enshrined in article 31, section IV of the Political Constitution of the United Mexican States due to the National Fiscal Coordination System.

6) To explain the above, the court explained the current framework between the Federation and the federal entities in tax matters, which revolved around the Fiscal Coordination Law published in the Official Gazette of the Federation on December 27, 1978. National System of Fiscal Coordination that ultimately evolved into a participation system, based on the formation of a General Participation Fund integrated with the income obtained by the Federation from the collection of federal taxes, whose distribution would be made between the federal entities and municipalities according to the criteria established in the law (population, percentage of collection, etc.)

7) That to address whether the schedular tax on the income of individuals was contrary to the principle of tax equity, it was first necessary to address the provisions of the Adherence Agreement to the National Fiscal Coordination System concluded between the state of Guanajuato and the Federation, as well as the provisions of the Value Added Tax Law in force at that time.

8) in this sense, it was evident that on October 9, 1979, Guanajuato entered into an Adhesion Agreement to the National Fiscal Coordination System with the Ministry of Finance and Public Credit. Also, in the fifth consideration point of the agreement, it was noted that the state of Guanajuato received fixed percentages of what was collected through federal taxes in exchange for said federal entity not maintaining in force state or municipal taxes that contravened the limitations indicated in the Value Added Tax Law and in the laws on special taxes that the Federation shall establish.

9) Hence, from the above it was implicitly derived that as of the entry into force of the National Fiscal Coordination System, the Legislature of the state of Guanajuato removed from its sphere of competence its attribution to create contributions that fall on taxable events taxed by federal taxes; without this—supposedly—implying a temporary renunciation of the power that constitutionally granted it, but rather the development of it through its omissive expression, in order to obtain resources via participation in the collection received from federal taxes.

10) On the other hand, it was clear from the systematic interpretation of articles 41 and 43 of the current Value Added Tax Law that the states that had adhered to the National Fiscal Coordination System were constrained not to establish contributions that tax acts or activities for which the Value Added Tax had to be paid. Also, under the reform to article 43 of the aforementioned law on December 1, 2004, and derived from the agreements approved in the National Convention of Public Finance, the federal entities were authorized to establish schedular taxes on the income obtained by individuals from the provision of professional services, from granting the temporary use or enjoyment of real estate, from the sale of real estate or business activities.

11) That is why it was evident that the Legislature of the State of Guanajuato took into consideration, for the establishment of the schedular tax on the income of individuals, both the agreements approved in the National Convention of Public Finance, as well as the provisions of Article 43. of the Value Added Tax Law, which allowed it to establish this tax without contravening the Agreement of Adherence to the National Fiscal Coordination System and, at the same time, not creating taxes on the income that legal entities generated and that were already taxed by a federal tax—Value Added Tax Law—.

12) Then, if for legal entities the taxing power of the Legislature of the State of Guanajuato was limited under the express and concrete reservation in favor of the Federation, it was justified that in the schedular tax, they were only considered as subjects of the aforementioned tax individuals, since if it was not limited to these, the legislative act would contravene article 43 of the Value Added Tax Law. Therefore, the legislature temporarily lacks the power to impose on legal entities any tax on the activities that cause the schedular tax, complementing and supporting the previous argument with the following binding precedent: FISCAL COORDINATION BETWEEN THE FEDERATION AND THE STATES. EFFECTS OF THE CELEBRATION OF ACCESSION AGREEMENTS TO THE NATIONAL SYSTEM REGARDING LOCAL TAX POWER[14].

13) Finally, due to all of the above mentioned, the schedular tax on the income of individuals did not violate the principle of tax equity by taxing only their income and not those received by legal entities since the state lawmakers of Guanajuato had an objective and reasonable justification for not considering them as subject to said tax, considering that they were not in equal circumstances with respect to the tax power of the legislative body of said state due to the Fiscal Coordination Law and the respective agreement celebrated by the federal entity

By Omar Gómez

Tax and Administrative Attorney in Mexico

Partner at beLegal abogados S.C

Abogados en Ciudad Juárez, Chihuahua

Visit www.belegalabogados.mx for more legal info.

[1] Title: 1a. XCIV/2007. First Chamber of the Mexican Supreme Court of Justice. Ninth Judicial Epoch. Non Binding Precedent (tesis aislada) Digital Record: 172507.

[2] Article 9.- The individuals who, in the territory of the State of Guanajuato, obtain income in cash, in goods, in credit, in services or in any other type, for perform the following activities:

I.- For the provision of professional services;

II.- For the granting of temporary use or enjoyment of real estate, located in the territory of the State; and

III.- For carrying out business activities.

individuals not resident in the State, who carry out business activities or provide professional services in the State, through a permanent establishment, for the income attributable to it, are also required to pay this tax. […].

[3] Article 14.- For the purposes of this Section, income from professional services is considered income from the provision of a professional service. It is understood that the income from the provision of an independent personal service is obtained in its entirety by the person providing the service.

[4] Article 16.- The taxpayers referred to in this Section shall make monthly provisional payments on account of the tax for the year, no later than the 17th day of the month immediately following the month to which the payment corresponds, by means of a declaration that they shall present to the authorized offices by the Ministry of Finance and Administration.

The provisional payment shall be determined by subtracting from the total income obtained in the month for which the declaration is made, the deductions for the same period referred to in the previous article. The rate established annually by the Income Law for the State of Guanajuato shall be applied to the result obtained.

When taxpayers provide professional services to legal entities, they must retain for the corresponding tax the amount resulting from applying the 2% rate on the amount of payments made to them, without any deduction, and must provide the taxpayers proof of withholding. These withholdings must be reported, where appropriate, together with those indicated in article 6 of this Law. The tax withheld in the terms of this paragraph shall be creditable against the tax payable that results in provisional payments in accordance with this article.

The tax for the year shall be calculated by reducing the authorized deductions corresponding to the same period to the total income obtained. The rate established annually by the Income Law for the State of Guanajuato shall be applied to the result. Against the annual tax calculated in the terms of this paragraph, the amount of provisional payments made during the calendar year may be credited. The annual declaration referred to in this paragraph shall be presented in the month of April of the following year, before the authorized offices.

[5] Article 17.- Those who sporadically obtain income derived from the provision of professional services during the year shall cover as a provisional payment on account of the annual tax the amount resulting from applying the rate established annually by the Income Law for the State of Guanajuato on the income received, without any deduction. The provisional payment shall be made by means of a declaration that shall be presented to the authorized offices within 15 business days after obtaining the income. These taxpayers shall be relieved of the obligation to keep books and records.

When the income received sporadically derives from payments made by a legal entity, the taxpayer who makes the payment referred to in the previous paragraph may prove against it the withholding made in the terms of the previous article.

Now, in the event that the taxpayers referred to in this article have a premises as a permanent establishment to provide professional services, the income from said services shall not be considered obtained sporadically, in such a way that the provisions of this article shall apply to them.

[6] Article 18.- Taxpayers, individuals subject to payment of the tax established in this Section, in addition to the obligations established in other articles of this Law and in the other tax provisions, shall have the following:

I.- Request your registration in the State Taxpayer Registry

II.- Keep accounting in accordance with the Tax Code for the State of Guanajuato, or, keep a book of income and expenses and record of investments and deductions;

III.- Issue and keep receipts that prove the income they receive, which must meet the requirements established in the Tax Code for the State of Guanajuato.

When the consideration covered by the voucher is collected in a single payment, it must indicate the total amount of the transaction. If the consideration was collected in installments, the receipt must also indicate the amount of the installment being covered at that time;

IV.- Present provisional and annual declarations; and

V.- Maintain the accounting and receipts of the respective entries, as well as those necessary to prove that the tax obligations have been met, in accordance with the provisions of the Tax Code for the State of Guanajuato.

[7] Article 43. – The Federal Entities may establish schedular taxes on the income obtained by individuals who receive income from the provision of professional services, from granting the temporary use or enjoyment of real estate, from the sale of real estate, or from business activities, without being considered a breach of the agreements entered into with the Ministry of Finance and Public Credit or of article 41 of this Law, when said taxes have the following characteristics:

I. In the case of individuals who obtain income from the provision of professional services, the tax rate that may be established shall be between 2% and 5%.

For the purposes of this section, income from the provision of professional services shall be understood as remuneration derived from independent personal services that are not assimilated to income from the provision of subordinate personal services, in accordance with article 110 of the Income Tax Law. The Federal Entities may tax, within the schedular tax on salaries or wages, independent personal income that is assimilated to income from the provision of a subordinate personal service.

The Federal Entities that establish the tax referred to in this section may only consider as subject to said tax, the taxable profit of the taxpayers that is attributed to the fixed bases in which they provide the services found in the Federal Entity of that is treated. When services are provided outside the fixed base, it shall be considered that the activity is carried out in the premises that serve as a base for the person providing said services.

When a taxpayer has fixed bases in two or more Federal Entities, to determine the tax that corresponds to each of them, the taxable profit obtained must be considered «for all the fixed bases that it has, and the result shall be divided between them in the proportion that the income obtained by each fixed base represents, with respect to the total income.

II. In the case of individuals who obtain income by granting the temporary use or enjoyment of real estate, the tax rate that may be established shall be between 2% and 5%.

The tax on income for granting the temporary use or enjoyment of real estate shall correspond to the Federal Entity where the property in question is located, regardless of whether the taxpayer has its tax domicile outside said Federal Entity.

III. In the case of individuals who obtain income from the sale of real estate, the tax rate that may be established shall be between 2% and 5%, and must be applied to the gain obtained from the sale of real estate located in the Entity. Federal Entity in question, regardless of whether the taxpayer has its tax domicile outside of said Federal Entity.

IV. In the case of individuals who obtain income from business activities, the tax rate that may be established shall be between 2% and 5%.

The Federal Entities that establish the tax referred to in this section may only tax the taxable profit obtained by taxpayers, by the establishments, branches or agencies located in the Federal Entity in question.

When a taxpayer has establishments, branches or agencies, in two or more Federal Entities, to determine the tax that corresponds to each of them, the sum of the taxable profit obtained by all the establishments, branches or agencies that it has must be considered, and the result shall be divided among these in the proportion represented by the income obtained by each establishment, branch or agency, with respect to the total income.

In the case of natural persons who pay taxes under the terms of Section III of Chapter II of Title IV of the Income Tax Law, the Federal Entities may estimate the tax utility of said taxpayers and determine the tax by establishing fixed fees.

The Federal Entities may establish different rates within the limits established in this article for each of the scheduled taxes referred to in this article.

The base of the schedular taxes referred to in this article must consider the same income and the same deductions that are established in the federal Income Tax Law, for income similar to those contemplated in the aforementioned scheduled taxes, not including the local schedular tax.

Likewise, the Federal Entities may agree with the Federation, through the Ministry of Finance and Public Credit, that the local taxes that may be established in their Federal Entity are paid in the same federal income tax returns.

[8] Title: P./J. 10/2003. Plenary session of the Mexican Supreme Court of Justice. Ninth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 184291.

[9] The best way to argue that double or even triple taxation in Mexico on the same sources of income is ruinous is through an accounting expert witness in tax and financial accounting, who are neither easy to find nor cheap.

[10] Title: P. 23. Plenary session of the Mexican Supreme Court of Justice.Eighth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 206079.

[11] Title: P. 24. Plenary session of the Mexican Supreme Court of Justice.Eighth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 206023.

[12] Title: P./J. 41/97. Plenary session of the Mexican Supreme Court of Justice. Ninth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 198403.

[13] Title: P./J. 42/97. Plenary session of the Mexican Supreme Court of Justice. Ninth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 198402.

[14] Title: 2a./J. 17/2001. Second Chamber of the Mexican Supreme Court of Justice. Ninth Judicial Epoch. Binding Precedent (Jurisprudencia) Digital Record: 189752.

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