Letter 500-05-2023-21260 communicating the definitive global list pursuant to the fourth paragraph of Article 69-B of the Federal Fiscal Code

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DOF: 01/12/2023

LETTER 500-05-2023-21260 whereby the definitive global list is communicated pursuant to the fourth paragraph of Article 69-B of the Federal Fiscal Code

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

Letter 500-05-2023-21260

Subject:

The definitive global list is communicated pursuant to the fourth paragraph of Article 69-B of the Federal Fiscal Code.

The Central Administration of Strategic Tax Enforcement, 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 Federal Official Gazette on December 15, 1995, reformed by Decree published in the same Federal Official Gazette 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 Federal Official Gazette 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 Finance 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 whereby various powers are delegated to the Public Servants of the Tax Administration Service, published in the Federal Official Gazette 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 the first and second paragraphs of article 69-B 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 aforementioned tax authorities, in order to comply with the second paragraph of article 69-B 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 Federal Official Gazette (DOF) in the terms specified in annex 1, section B and C, of this letter, which is an integral part thereof, the foregoing 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 could make statements and provide the evidence they considered pertinent to disprove the facts made known through the aforementioned 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 disprove the facts indicated in the letters in question, 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 definitive individual resolution, as well as the publication of their names, denominations or corporate names in the list of taxpayers who did not disprove the facts made known and therefore, would be definitively in the situation referred to in the first paragraph of the aforementioned article 69-B of the Federal Fiscal Code.

Once the period indicated in the previous paragraph had elapsed, and by virtue of the fact that the taxpayers during the period established in the second paragraph of article 69-B of the Federal Fiscal Code, did not appear before the corresponding tax authority despite being duly notified and, therefore, did not present any documentation tending to disprove the facts made known through the aforementioned individual letters, the warning was made effective and therefore the tax authorities proceeded to issue the definitive individual resolutions in which it was determined that by not having appeared before the authority they did not disprove the facts imputed to them, and, therefore, that the hypothesis provided for in the first paragraph of this article 69-B of the Federal Fiscal Code is definitively updated, this for the reasons exposed in said definitive resolutions.

It should be noted that the definitive resolutions indicated in the previous paragraph were duly notified in the terms indicated in the paragraphs preceding each of the taxpayers indicated in Annex 1, section D of this letter.

Based on 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 aforementioned 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 the aforementioned definitive resolutions, this Central Administration of Strategic Tax Enforcement 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 disprove the facts imputed to them and therefore, are definitively in the situation referred to in the first paragraph of the aforementioned article 69-B of the Federal Fiscal Code, for the reasons and grounds indicated in the definitive resolutions notified to each of them, which list will be published on the internet page of the Tax Administration Service ( www.sat.gob.mx ) as well as in the Federal Official Gazette, in order to consider, with general effects, that the tax receipts issued by said taxpayers do not produce nor produced any tax effect, just as the fifth paragraph of article 69-B of the Federal Fiscal Code declares; the foregoing, 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 who carry out this type of operations.

Sincerely,

Mexico City, September 15, 2023. - In substitution for absence of the Central Administrator of Strategic Tax Enforcement, of the Coordinator of Strategic Tax Enforcement and of the Administrators of Strategic Tax Enforcement " 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 Tax Enforcement " 7 ", L.C. Susana Herrera Maldonado .- Signature.

Annex 1 of letter number 500-05-2023-21260 dated September 15, 2023, corresponding to taxpayers who did NOT provide arguments or evidence to disprove the reason for which they were notified of 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 pursuant to the first and second paragraphs of article 69-B of the Federal Fiscal Code, in relation to article 69 of its Regulations.

RFC	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Individual Presumption Letter	Issuing Authority of Individual Presumption Letter	Notification Method to Taxpayer - Notice Boards (Date of Posting / Date of Effect)	Notification Method to Taxpayer - Personal Notification (Date / Date of Effect)	Notification Method to Taxpayer - Tax Mailbox (Date / Date of Effect)
1	CMA200428T62	COMERCIALIZADORA MARIMEZA, S.A. DE C.V.	500-51-00-01-01-2022-56979 dated December 06, 2022	Decentralized Administration of Federal Tax Audit of Sinaloa "1"	December 12, 2022 / December 13, 2022
2	GCC120706MPA	GRUPO CHER COMERCIAL, S.A. DE C.V.	500-05-2023-4184 dated March 13, 2023	Central Administration of Strategic Tax Enforcement	March 21, 2023 / March 22, 2023
3	SEO141204T41	SERVICIOS EMPRESARIALES OG, S.A. DE C.V. // In compliance with the sentence dated September 01, 2022, issued by the First Regional Chamber of the Northwest I, of the Federal Court of Administrative Justice, within the Nullity Trial 1896/21-01- 01-3	500-05-2023-4043 dated February 21, 2023	Central Administration of Strategic Tax Enforcement	February 22, 2023 / February 23, 2023

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

RFC	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Global Presumption Letter	Issuing Authority of Global Presumption Letter	Date of Notification on the Internet Page of the Tax Administration Service	Date on which Notification Took Effect
1	CMA200428T62	COMERCIALIZADORA MARIMEZA, S.A. DE C.V.	500-05-2023-3959 dated January 04, 2023	Central Administration of Strategic Tax Enforcement	January 04, 2023
2	GCC120706MPA	GRUPO CHER COMERCIAL, S.A. DE C.V.	500-05-2023-4297 dated April 03, 2023	Central Administration of Strategic Tax Enforcement	April 03, 2023
3	SEO141204T41	SERVICIOS EMPRESARIALES OG, S.A. DE C.V.	500-05-2023-4144 dated March 01, 2023	Central Administration of Strategic Tax Enforcement	March 01, 2023

Section C.- Notification in the Federal Official Gazette.

RFC	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Global Presumption Letter	Issuing Authority of Global Presumption Letter	Date of Notification in the Federal Official Gazette	Date on which Notification Took Effect
1	CMA200428T62	COMERCIALIZADORA MARIMEZA, S.A. DE C.V.	500-05-2023-3959 dated January 04, 2023	Central Administration of Strategic Tax Enforcement	February 07, 2023
2	GCC120706MPA	GRUPO CHER COMERCIAL, S.A. DE C.V.	500-05-2023-4297 dated April 03, 2023	Central Administration of Strategic Tax Enforcement	May 09, 2023
3	SEO141204T41	SERVICIOS EMPRESARIALES OG, S.A. DE C.V.	500-05-2023-4144 dated March 01, 2023	Central Administration of Strategic Tax Enforcement	April 07, 2023

Section D.- Notification of the DEFINITIVE RESOLUTION letter pursuant to the fourth paragraph of article 69-B of the Federal Fiscal Code.

RFC	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Definitive Resolution	Issuing Authority of Definitive Resolution	Notification Method to Taxpayer - Notice Boards (Date of Posting / Date of Effect)	Notification Method to Taxpayer - Personal Notification (Date / Date of Effect)	Notification Method to Taxpayer - Tax Mailbox (Date / Date of Effect)
1	CMA200428T62	COMERCIALIZADORA MARIMEZA, S.A. DE C.V.	500-51-00-01-01-2023-21537 dated May 02, 2023	Decentralized Administration of Federal Tax Audit of Sinaloa "1"	May 04, 2023 / May 08, 2023
2	GCC120706MPA	GRUPO CHER COMERCIAL, S.A. DE C.V.	500-05-2023-15841 dated July 10, 2023	Central Administration of Strategic Tax Enforcement	July 14, 2023 / July 31, 2023
3	SEO141204T41	SERVICIOS EMPRESARIALES OG, S.A. DE C.V.	500-05-2023-15543 dated June 21, 2023	Central Administration of Strategic Tax Enforcement	June 27, 2023 / June 28, 2023

Section E.- Additional Data of the Taxpayers.

RFC	Name, Denomination or Corporate Name of the Taxpayer	Tax Domicile	Preponderant Activity	Reason for Procedure
1	CMA200428T62	COMERCIALIZADORA MARIMEZA, S.A. DE C.V.	Culiacán, Sinaloa	Retail trade of new parts and accessories for automobiles, vans and trucks
2	GCC120706MPA	GRUPO CHER COMERCIAL, S.A. DE C.V.	Coyoacán, Mexico City	Wholesale trade of clothing
3	SEO141204T41	SERVICIOS EMPRESARIALES OG, S.A. DE C.V.	Mexicali, Baja California	Accounting and auditing services

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