Letter 500-05-2023-21167 through which the definitive global list is communicated in terms of Article 69-B, fourth paragraph of the Federal Fiscal Code — SHCP — MX

Official Gazette of the Federation (DOF): 26/09/2023

LETTER 500-05-2023-21167 through which the definitive global list is communicated in terms of Article 69-B, fourth paragraph of the Federal Fiscal Code

On the margin a seal with the National Shield, which says: United Mexican States.- TREASURY.- Secretariat of the Treasury and Public Credit.- Tax Administration Service.- General Administration of Federal Tax Audit.- Central Administration of Strategic Audit.

Letter: 500-05-2023-21167

Subject:

The definitive global list is communicated in terms

of Article 69-B, fourth paragraph of the

Federal Fiscal Code.

The Central Administration of Strategic Audit, attached to the General Administration of Federal Tax Audit of the Tax Administration Service, based on the provisions of Articles 16, first paragraph, of the Political Constitution of the United Mexican States; 1, 7, sections VII, XII and XVIII and 8, section III of the Law of the Tax Administration Service, published in the Official Gazette of the Federation on December 15, 1995, reformed by Decree published in the same Official Gazette of the Federation on June 12, 2003; 1, 2, first paragraphs, Section B, section III, subsection e), and second, 5, first paragraph, 13, section VI, 23, Section E, section I, in relation to Article 22 first paragraphs, section VIII, and last, numeral 5, of the Internal Regulations of the Tax Administration Service published in the Official Gazette of the Federation on August 24, 2015, effective from November 22, 2015, in accordance with the provisions of the first paragraph of the First Transitory Article of said Regulations and reformed by Decree reforming and adding various provisions of the Internal Regulations of the Secretariat of the Treasury and Public Credit and of the Internal Regulations of the Tax Administration Service, and by which the Internal Regulations of the National Customs Agency of Mexico are issued, published in the same official body on December 21, 2021, effective from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, section I, subsection a), of the Agreement through which various powers are delegated to the Public Servants of the Tax Administration Service, published in the Official Gazette of the Federation on June 23, 2016, effective from July 23, 2016, in accordance with the provisions of the First Transitory Article of said Agreement; as well as in Articles 33, last paragraph, 63, and 69-B first, fourth and fifth paragraphs of the Federal Fiscal Code, notifies the following:

Derived from the exercise of the powers and faculties indicated in Article 69-B, first and second paragraphs of the Federal Fiscal Code, the tax authorities cited in Annex 1 which is an integral part of this letter, detected that the taxpayers indicated in said Annex 1 issued tax receipts without having the assets, personnel, infrastructure or material capacity to provide the services or produce, market or deliver the goods covered by such receipts.

Once such situation was detected, the tax authority, in order to comply with Article 69-B, second paragraph, of the Federal Fiscal Code, as well as numeral 69 of the Regulations of said Code, issued an individual presumption letter to each of the taxpayers mentioned in said Annex 1, and in said letter the reasons and grounds were indicated for which the taxpayers were located in the hypothesis referred to in the first paragraph of Article 69-B of the Federal Fiscal Code.

Now then, the individual letters indicated in the preceding paragraph were notified to each taxpayer in the terms specified in Annex 1, Section A, of this letter, which is an integral part thereof.

On the other hand, the global list of presumption was notified on the internet page of the Tax Administration Service; and through publication in the Official Gazette of the Federation (DOF) in the terms specified in Annex 1, Section B and C, of this letter, which is an integral part thereof, the above in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Fiscal Code in force, in relation to Article 135 of the Federal Fiscal Code.

Attending to the provisions of the second paragraph of Article 69-B of the Federal Fiscal Code, in the individual presumption letters the tax authorities granted each taxpayer a period of fifteen business days counted from the last of the notifications previously made, so that they made statements and provided the evidence they considered pertinent to refute the facts made known through said letters, warned that if upon expiration of the granted period they did not provide the documentation and information and/or that which they exhibited, once valued, did not refute the facts indicated in the letters of the matter, proceedings would be carried out by said authorities in terms of the fourth paragraph of Article 69-B of the Federal Fiscal Code, first to notify them of the individual definitive resolution, as well as the publication of their names, denominations or corporate names in the list of taxpayers who did not refute the facts made known and therefore, would be definitively in the situation referred to in the first paragraph of said Article 69-B of the Federal Fiscal Code.

Once the period indicated in the previous paragraph had elapsed, and by virtue that those taxpayers during the period established in the second paragraph of Article 69-B of the Federal Fiscal Code, in exercise of the right provided in said legal precept, presented, through the means indicated in the own individual resolutions, diverse information, documentation and arguments in order to refute the facts made known in the individual letters indicated above, and said authorities proceeded to the admission and valuation of the same.

Derived from the valuation mentioned in the preceding paragraph, and by virtue that with the arguments manifested and evidence provided by those taxpayers the referred authorities considered that those taxpayers did not refute the facts that were imputed to them in the individual presumption letters already indicated, the same resolved the conducive and proceeded to the issuance of the definitive resolutions in which the reasons, motives and grounds were indicated for why they did not refute said facts; resolutions that were duly notified in the terms indicated in the paragraphs preceding to each of the taxpayers indicated in Annex 1, Section D, of this letter.

For the foregoing and, taking into account that the fourth paragraph of Article 69-B of the Federal Fiscal Code, indicates that in no case will the list be published before thirty business days after the notification of the resolution and that, to date said period has elapsed since the notification of the resolution and, furthermore the cited authorities have not been notified of any resolution or sentence granted in favor of those taxpayers that orders the suspension or declares the nullity or revocation of the procedure provided for in Article 69-B of the Federal Fiscal Code, that has been initiated against them; therefore, with the purpose of giving full compliance to the Third Resolution contained in said definitive resolutions, this Central Administration of Strategic Audit, attached to the General Administration of Federal Tax Audit of the Tax Administration Service, in support of the tax authorities indicated in Annex 1 of the present, proceeds to add the names, denominations or corporate names of the taxpayers indicated in Annex 1 of this letter, in the list of taxpayers who did not refute the facts that were imputed to them and therefore, are definitively in the situation referred to in the first paragraph of said Article 69-B of the Federal Fiscal Code, for the reasons and grounds indicated in the definitive resolutions notified to each of them, list that will be published on the internet page of the Tax Administration Service ( www.sat.gob.mx ) as well as in the Official Gazette of the Federation, in order to consider, with general effects, that the tax receipts issued by said taxpayers produce nor produced any tax effect whatsoever, just as the fifth paragraph of Article 69-B of the Federal Fiscal Code declares; the above, since it is of public interest that the invoicing of non-existent operations be stopped, as well as that society knows who are those taxpayers that carry out this type of operations.

Respectfully

Mexico City, August 28, 2023.- In substitution for absence of the Central Administrator of Strategic Audit, of the Coordinator of Strategic Audit and of the Administrators of Strategic Audit " 1 " , " 2 " , " 3 " , " 4 " , " 5 " and " 6 " based on Articles 4, fourth paragraph, and 22, last paragraph, numeral 5 subsection h), of the Internal Regulations of the Tax Administration Service in force,

Signature: Administrator of Strategic Audit " 7 " , L.C. Susana Herrera Maldonado .- Signature Mark.

Annex 1 of letter number 500-05-2023-21167 dated August 28, 2023, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT refute the reason for which they were notified the presumption letter, reason for which, the situation referred to in the first paragraph of Article 69-B of the Federal Fiscal Code was DEFINITIVELY updated.

Section A.- Notification of the PRESUMPTION LETTER in accordance with the first and second paragraphs of Article 69-B of the Federal Fiscal Code, in relation to Article 69 of its Regulations.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of individual presumption letter	Issuing Authority of the individual presumption letter	Notification Method to the Taxpayer: Court Boards of the Authority	Notification Method to the Taxpayer: Personal Notification	Notification Method to the Taxpayer: Notification by Tax Mailbox
				Date of fixation on the Court Boards of the Fiscal Authority	Date on which the notification took effect	Date of notification	Date on which the notification took effect	Date of notification	Date on which the notification took effect
1	LIC170911CI3	LINEA INTEGRAL AL COMERCIO PETROLERO, S. DE R.L. DE C.V.	500-57-00-04-01-2019-004812 dated October 30, 2019	Decentralized Administration of Tax Audit of Tabasco "1"	06 de noviembre de 2019	07 de noviembre de 2019
2	MFD190529GF1	METODOS FINANCIEROS PARA EL DESARROLLO, S.C.	500-05-2022-29359 dated December 14, 2022	Central Administration of Strategic Audit	02 de enero de 2023	03 de enero de 2023
3	SIV180514MF6	SERVICIOS INTEGRALES VABOK, S.A. DE C.V.	500-05-2019-35938 dated October 31, 2019	Central Administration of Strategic Audit	05 de noviembre de 2019	06 de noviembre de 2019

Section B.- Notification on the Internet Page of the Tax Administration Service

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of global presumption letter	Issuing Authority of the global presumption letter	Date of notification on the internet page of the Tax Administration Service	Date on which the notification took effect
1	LIC170911CI3	LINEA INTEGRAL AL COMERCIO PETROLERO, S. DE R.L. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	02 de diciembre de 2019	03 de diciembre de 2019
2	MFD190529GF1	METODOS FINANCIEROS PARA EL DESARROLLO, S.C.	500-05-2023-3959 dated January 04, 2023	Central Administration of Strategic Audit	04 de enero de 2023	05 de enero de 2023
3	SIV180514MF6	SERVICIOS INTEGRALES VABOK, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	02 de diciembre de 2019	03 de diciembre de 2019

Section C.- Notification in the Official Gazette of the Federation.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of global presumption letter	Issuing Authority of the global presumption letter	Date of notification in the Official Gazette of the Federation	Date on which the notification took effect
1	LIC170911CI3	LINEA INTEGRAL AL COMERCIO PETROLERO, S. DE R.L. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	26 de diciembre de 2019	08 de enero de 2020
2	MFD190529GF1	METODOS FINANCIEROS PARA EL DESARROLLO, S.C.	500-05-2023-3959 dated January 04, 2023	Central Administration of Strategic Audit	07 de febrero de 2023	08 de febrero de 2023
3	SIV180514MF6	SERVICIOS INTEGRALES VABOK, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	26 de diciembre de 2019	08 de enero de 2020

Section D.- Notification of the DEFINITIVE RESOLUTION letter in accordance with the fourth paragraph of Article 69-B of the Federal Fiscal Code.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of definitive resolution	Issuing Authority of the definitive resolution	Notification Method to the Taxpayer: Court Boards of the Authority	Notification Method to the Taxpayer: Personal Notification	Notification Method to the Taxpayer: Notification by Tax Mailbox
				Date of fixation on the Court Boards of the Fiscal Authority	Date on which the notification took effect	Date of notification	Date on which the notification took effect	Date of notification	Date on which the notification took effect
1	LIC170911CI3	LINEA INTEGRAL AL COMERCIO PETROLERO, S. DE R.L. DE C.V. // In compliance with the sentence dated May 31, 2021, issued by the Regional Chamber of Tabasco and Auxiliary of the Federal Court of Administrative Justice, within the Nullity Trial 685/20-26-01-04	500-57-00-04-01-2023-00133 dated January 30, 2023	Decentralized Administration of Tax Audit of Tabasco "1"	03 de febrero de 2023	07 de febrero de 2023
2	MFD190529GF1	METODOS FINANCIEROS PARA EL DESARROLLO, S.C.	500-05-2023-4392 dated May 10, 2023	Central Administration of Strategic Audit	16 de mayo de 2023	17 de mayo de 2023
3	SIV180514MF6	SERVICIOS INTEGRALES VABOK, S.A. DE C.V. // In compliance with the sentence dated December 01, 2021, issued by the Regional Chamber of the Northwest II, of the Federal Court of Administrative Justice, in the Nullity Trial 1195/20-02-01- 5.	500-05-2023-4126 dated March 03, 2023	Central Administration of Strategic Audit	09 de marzo de 2023	10 de marzo de 2023

Section E.- Additional Data of the Taxpayers.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Tax Domicile	Preponderant Activity	Reason for Procedure
1	LIC170911CI3	LINEA INTEGRAL AL COMERCIO PETROLERO, S. DE R.L. DE C.V.	Villahermosa, Tabasco.	Extraction of crude oil and extraction of crude hydrocarbons in gaseous state (natural gas)	Absence of assets, Absence of personnel.
2	MFD190529GF1	METODOS FINANCIEROS PARA EL DESARROLLO, S.C.	Aguascalientes, Aguascalientes	Consulting services in administration	Absence of assets, Absence of personnel, Lack of Infrastructure, Without material capacity.
3	SIV180514MF6	SERVICIOS INTEGRALES VABOK, S.A. DE C.V.	Hermosillo, Sonora	Other Intermediaries of retail trade	Absence of assets, Absence of personnel.

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