A dictamen fiscal is an accountant’s audit opinion on a taxpayer’s financial statements for tax purposes. Article 52 of Mexico’s Federal Tax Code allows only registered persons to sign one. Registration is open to Mexicans “que tengan título de contador público registrado ante la Secretaría de Educación Pública” (who hold a title of public accountant registered with the Ministry of Public Education).
They must also have belonged to a recognized professional association for at least three years, hold a certification and have at least three years of experience preparing tax audits. Foreign accountants qualify only where an international treaty allows it.