Notice 500-05-2024-12710 Communicating the Definitive Global List Under Article 69-B, Paragraph 3 of the Federal Tax Code in Force Until July 24, 2018

DOF: 20/06/2024

OFFICE 500-05-2024-12710 communicating the definitive global list under Article 69-B, paragraph 3 of the Federal Tax Code in force until July 24, 2018

At the margin, a seal with the National Coat of Arms, which reads: United Mexican States.- TREASURY.- Ministry of

Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit

Strategic Audit Central Administration.

Office: 500-05-2024-12710

Subject:

Communicating the definitive global list under

Article 69-B, paragraph 3 of the

Federal Tax Code in force until

July 24, 2018.

The Strategic Audit Central Administration, attached to the General Administration of Federal Fiscal 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, fractions VII, XII and XVIII and

8, fraction III of the Law of the Tax Administration Service, published in the Official Gazette of the Federation on December 15, 1995, amended by Decree published in the same Official Gazette on June 12, 2003; 1, 2, first paragraph, section B, fraction III, subsection e), and second, 5,

first paragraph, 13, fraction VI, 23, section E, fraction I, in relation to Article

22 first paragraphs,

fraction 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, in force from November 22, 2015, in accordance with the provisions of the first paragraph of the First Transitory Article of said Regulations and

amended by Decree amending and adding various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Tax Administration Service, and by which the Internal Regulations of the National Agency of Customs of Mexico are issued,

published in the same official organ on December 21, 2021, in force from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third,

fraction I, subsection a), of the Agreement by 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, in force from July 23, 2016, in accordance with the provisions of the First Transitory Article of said Agreement; as well as Articles 33, last paragraph, 63, of the Federal Tax Code in force and 69-B, paragraphs first, third and fourth of the Federal Tax Code in force until July 24,

2018, in relation to the Second Transitory Article of the "DECREE amending Article 69-B of the Federal Tax Code", published in the Official Gazette of the Federation on June 25,

2018 and Transitory Article Twenty-Fourth, fraction I) of the Fiscal Miscellany Resolution for 2024,

published in the Official Gazette of the Federation on December 29, 2023, notifies the following:

As a result of the exercise of the powers and faculties indicated in Article 69-B, paragraphs first and

second of the Federal Tax Code in force until July 24, 2018, the tax authorities

cited in Annex 1, which is an integral part of this office, detected that the taxpayers

indicated in the aforementioned Annex 1 issued fiscal receipts without having the assets, personnel,

infrastructure or material capacity to provide the services or produce, commercialize or deliver the goods

that cover such receipts.

Having detected such a situation, the tax authority in order to comply with Article 69-B, paragraph second, of the

Federal Tax Code in force until July 24, 2018, as well as numeral 69 of the Regulations

of said Code, issued an individual presumption notice to each of the taxpayers mentioned in

the aforementioned Annex 1, and in said notice the reasons and grounds were indicated by which the taxpayers

were located in the hypothesis referred to in the first paragraph of Article 69-B of the Federal Tax Code

in force until July 24, 2018.

Now, the individual notices indicated in the preceding paragraph were notified to each

taxpayer in the terms specified in Annex 1, section A, of this office, which is part

integral of it.

On the other hand, the global list of presumption was notified on the website of the

Tax Administration Service; and through publication in the Official Gazette of the Federation (DOF) in the terms

specified in Annex 1, sections B and C, of this office, which is an integral part of it, the above

in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax

Code in force, in correlation with Article 135 of the Federal Tax Code.

Attending to the provisions of the second paragraph of Article 69-B of the Federal Tax Code

in force until July 24, 2018, in the individual presumption notices the tax authorities granted

to each taxpayer a period of fifteen business days counted from the last of the notifications before

effective, to make the statements and provide the evidence they considered pertinent

to rebut the facts made known through the aforementioned notices, warned that if the

granted period elapsed without providing the documentation and information and/or the that exhibited, once valued, did not

rebut the facts indicated in the notices of merit, it would proceed by said authorities in

terms of the third paragraph of Article 69-B of the Federal Tax Code in force until July 24,

2018, first to notify them the definitive individual resolution, as well as the publication of their names,

denominations or trade names in the list of taxpayers who did not rebut the facts given

known and therefore, would be in definitive form in the situation referred to in the first paragraph of the

cited Article 69-B of the Federal Tax Code in force until July 24, 2018.

Once the period indicated in the previous paragraph has elapsed, and in virtue that those taxpayers during the

period established in the second paragraph of Article 69-B of the Federal Tax Code in force until

July 24, 2018, in exercise of the right provided for in the cited legal provision, presented, through

the means indicated in the individual resolutions themselves, various information, documentation and

arguments in order to rebut the facts made known in the individual notices indicated

above, and said authorities proceeded to the admission and valuation of the same.

As a result of the valuation mentioned in the preceding paragraph, and in virtue that with the arguments

manifested and evidence provided by those taxpayers the aforementioned authorities considered that

those taxpayers did not rebut the facts that were imputed to them in the individual presumption notices

already indicated, the same resolved what was appropriate and proceeded to the issuance of the definitive resolutions

in which the reasons, motives and grounds were indicated for why they did not rebut said facts;

resolutions that were duly notified in the terms indicated in the preceding paragraphs to

each of the taxpayers indicated in Annex 1, section D, of this office.

For the above and, taking into account that the third paragraph of Article 69-B of the Federal

Tax Code in force until July 24, 2018, in relation to the Second Transitory Article

of the "DECREE amending Article 69-B of the Federal Tax Code", published in the

Official Gazette of the Federation on June 25, 2018, states that in no case will the list be published before

the thirty business days following the notification of the resolution and that, to date, said

period has elapsed since the notification of the resolution and, in addition, 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 Tax Code,

in force until July 24, 2018, that has been initiated against them; therefore, with the aim of giving full

compliance to Resolutive Third contained in the aforementioned definitive resolutions, this Administration

Central of Strategic Audit, attached to the General Administration of Federal Fiscal 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 trade names of the taxpayers

indicated in Annex 1 of this office, in the list of taxpayers who did not rebut the facts

that were imputed to them and therefore, are in definitive form in the situation referred to in the first

paragraph of the cited Article 69-B of the Federal Tax Code in force until July 24, 2018, for the

reasons and grounds indicated in the definitive resolutions notified to each of them, list that

will be published on the website 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 fiscal receipts

issued by said taxpayers do not produce nor produced any fiscal effect whatsoever, as declared by the fourth paragraph of Article 69-B of the Federal Tax Code in force until July 24,

2018; this being so, since it is in the public interest to stop the billing of operations

nonexistent, as well as that society knows who are those taxpayers who carry out this

type of operations.

Sincerely

Mexico City, May 27, 2024.- In substitution for the absence of the Central Administrator of

Strategic Audit, from the Coordinator of Strategic Audit, from the Administrator of Fiscalization

Strategic "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, signs: L.C.

Susana Herrera Maldonado, Administrator of Strategic Audit "7".- Rubric.

Annex 1 of office number 500-05-2024-12710 dated May 28, 2024, corresponding to

taxpayers who DID provide arguments and/or evidence, but DID NOT rebut the reason for which they

were notified of the presumption notice, for which reason, the situation was updated DEFINITIVELY

referred to in the first paragraph of Article 69-B of the Federal Tax Code.

Section A.- Notification of the PRESUMPTION OFFICE in accordance with paragraphs first and second

of Article 69-B of the Federal Tax Code, in relation to Article 69 of its Regulations.

RFC

Name,

denomination or

trade name of the

Taxpayer

Number and

date of office

individual of

presumption

Authority

issuer of the

individual office

of presumption

Means of notification to the taxpayer

Authority's files

Personal notification

Notification by Tax Box

Date of

fixing in

the files

of the

Fiscal Authority

Date on

which it

took effect

the notification

Date of

notification

Date on which

it took effect

the notification

Date of

notification

Date on which

it took effect

the notification

1

RGA111103QB5

RIVAS, GUERRERO

ADVISORS, S.C.

500-42-00-08-

00-2017-07183

dated October 31

2017

Administration

Deconcentrated

of Fiscal Audit

of Nuevo León "2"

January 12

2018

February 07

2018

Section B.- Notification on the website of the Tax Administration Service

RFC

Name, denomination or

trade name of the

Taxpayer

Number and date of

global office of

presumption

Authority issuer of the

global office of

presumption

Date of notification on the

website of the

Tax Administration Service

Date on which it took effect

the notification

1

RGA111103QB5

RIVAS, GUERRERO

ADVISORS, S.C.

500-05-2018-13380 of

dated April 30 of

2018

Central Administration of

Strategic Audit

May 01, 2018

May 02, 2018

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

RFC

Name, denomination or

trade name of the

Taxpayer

Number and date of

global office of

presumption

Authority issuer of the

global office of

presumption

Date of notification in the

Official Gazette of the

Federation

Date on which it took effect

the notification

1

RGA111103QB5

RIVAS, GUERRERO

ADVISORS, S.C.

500-05-2018-13380 of

dated April 30 of

2018

Central Administration of

Strategic Audit

May 22, 2018

May 23, 2018

Section D.- Notification of the OFFICE OF DEFINITIVE RESOLUTION in accordance with the third paragraph of

Article 69-B of the Federal Tax Code in force until July 24, 2018.

RFC

Name, denomination or

trade name of the

Taxpayer

Number and date of

definitive resolution

Authority issuer

of the resolution

definitive

Means of notification to the taxpayer

Authority's files

Personal notification

Notification by Tax Box

Date of

fixing in

the

files of

the

Fiscal Authority

Date on

which it took effect

the

notification

Date of

notification

Date on which

it took effect

the notification

Date of

notification

Date on which

it took effect

the

notification

1

RGA111103QB5

RIVAS, GUERRERO

ADVISORS, S.C.

500-42-00-08-00-

2018-06423 of

dated November 13

2018

Administration

Deconcentrated of

Fiscal Audit of

Nuevo León "2"

November 23

2018

November 26

2018

Section E.- Additional data of taxpayers.

RFC

Name, denomination or

trade name of the Taxpayer

Fiscal Address

Predominant Activity

Reason for the Procedure

1

RGA111103QB5

RIVAS, GUERRERO

ADVISORS, S.C.

Guadalupe, Nuevo León

Accounting and audit services

Absence of Personnel, Lack of

Infrastructure, Without Material

Capacity

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