Regulatory Alerts2024-08-09 | DOF 5735615Added
Notice 500-05-2024-12819 Communicating the Definitive Global List under Article 69-B, Paragraph Four of the Federal Tax Code
The Strategic Fiscal Audit Central Administration of the Tax Administration Service publishes the definitive global list of four taxpayers whose tax invoices are deemed to have no fiscal effect because they failed to rebut the presumption that they issued invoices without assets, personnel, infrastructure, or material capacity. The listed entities—Alianza Regional Educativa, Comercializadora Worth, HB Segind, and Opciones en Capacitacion Continua—were notified of individual presumption notices and final resolutions but did not successfully disprove the allegations of issuing invoices for non-existent operations. Consequently, their names are published to establish that their issued fiscal receipts produce no fiscal effect for any taxpayer.
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DOF: 09/08/2024
OFFICE 500-05-2024-12819 through which the definitive global list is communicated under Article 69-B, fourth paragraph of the Federal Tax Code
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
- Central Administration of Strategic Audit.
Office: 500-05-2024-12819
Subject:
The definitive global list is communicated under Article 69-B, fourth paragraph of the Federal Tax Code.
The Central Administration of Strategic Audit, attached to the General Administration of Federal Fiscal Audit of the Tax Administration Service, based on what is established in 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 Federations on December 15, 1995, reformed by Decree published in the same Official Gazette of the Federations on June 12, 2003; 1, 2, paragraphs first, section B, fraction III, subsection e), and second, 5, first paragraph, 13, fraction VI, 23, section E, fraction I, in relation with article 22 paragraphs first, fraction VIII, and last, numeral 5, of the Internal Regulations of the Tax Administration Service published in the Official Gazette of the Federations on August 24, 2015, in force from November 22, 2015, in conformity with what is established in the first paragraph of the First Transitory Article of said Regulations and reformed through Decree by which various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Tax Administration Service are reformed and added, 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 01, 2022, in conformity with what is established in the First Transitory Article of said Decree; Third Article, fraction I, subsection a), of the Agreement by which various attributions are delegated to the Public Servants of the Tax Administration Service, published in the Official Gazette of the Federations on June 23, 2016, in force from July 23, 2016, in conformity with what is established in the First Transitory Article of said Agreement; as well as in articles 33, last paragraph, 63, and 69-B paragraphs first, fourth and fifth of the Federal Tax Code, notifies the following:
As a result of the exercise of the attributions and faculties indicated in article 69-B, paragraphs first and second of the Federal Tax Code, 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 situation, the tax authority, in order to comply with article 69-B, second paragraph, of the Federal Tax Code, as well as with numeral 69 of the Regulations of said Code, issued an office of individual presumption to each of the taxpayers mentioned in the aforementioned Annex 1, and in said office 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 Tax Code.
Now, the individual offices indicated in the preceding paragraph were notified to each taxpayer in the terms specified in Annex 1, section A, of this office, which is an integral part of the same.
On the other hand, the global list of presumption was notified on the internet page of the Service of Tax Administration; and through publication in the Official Gazette of the Federations (DOF) in the terms specified in annex 1, sections B and C, of this office, which is an integral part of the same, the above in conformity with the precedence established in article 69, first paragraph of the Regulations of the Federal Tax Code in force, in relation with article 135 of the Federal Tax Code.
Attending what is established by the second paragraph of article 69-B of the Federal Tax Code, in the offices of individual presumption the tax authorities granted each taxpayer a term of fifteen business days counted from the last of the notifications previously made, to make the manifestations and provide the proofs they considered pertinent to rebut the facts given to know through the aforementioned offices, warned that if after the granted term they did not provide the documentation and information and/or that which they exhibited, once valued, did not rebut the facts indicated in the offices of merit, it would proceed by said authorities in terms of the fourth paragraph of article 69-B of the Federal Tax Code, first to notify them the individual definitive resolution, as well as to the publication of their names, denominations or trade names in the list of taxpayers who did not rebut the facts given to know and therefore, would be in definitive form in the situation referred to in the first paragraph of the aforementioned article 69-B of the Federal Tax Code.
Once the term indicated in the preceding paragraph has elapsed, and in virtue that those taxpayers during the term established in the second paragraph of article 69-B of the Federal Tax Code, in exercise of the right provided in the aforementioned legal precept, presented, through the means indicated in the own individual resolutions, various information, documentation and arguments in order to rebut the facts given to know in the individual offices 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 proofs provided by those taxpayers the aforementioned authorities considered that those taxpayers did not rebut the facts that were imputed to them in the individual offices of presumption 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 fourth paragraph of article 69-B of the Federal Tax Code, indicates that in no case will the list be published before the thirty business days subsequent to the notification of the resolution and that, at the date said term 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 in article 69-B of the Federal Tax Code, that has been initiated against them; therefore, with the purpose of giving full compliance to the Third Resolutive contained in the aforementioned resolutions definitive, this Central Administration 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 to which the first paragraph of the aforementioned article 69-B of the Federal Tax Code refers, for the reasons and grounds indicated in the definitive resolutions notified to each of them, a 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 Federations, to effect considering, with general effects, that the fiscal receipts issued by said taxpayers do not produce nor produced any fiscal effect whatsoever, as declared by the fifth paragraph of article 69-B of the Federal Tax Code; the above, since it is of public interest that the invoicing of non-existent operations be stopped, as well as that society knows who those are the taxpayers who carry out this type of operations.
Sincerely
Mexico City, June 25, 2024. - Central Administrator of Strategic Audit, L.C. Rubén Martín López Rodríguez. - Rubric.
Annex 1 of office number 500-05-2024-12819 dated June 25, 2024, corresponding to taxpayers who DID provide arguments and/or proofs, but DID NOT rebut the reason for which they were notified of the presumption office, reason for which, the situation was updated DEFINITIVELY that refers to the first paragraph of article 69-B of the Federal Tax Code.
Section A.- Notification of the OFFICE OF PRESUMPTION in accordance with paragraphs first and second of article 69-B of the Federal Tax Code, in relation with article 69 of its Regulations.
R.F.C.
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
Court of the authority
Personal notification
Notification by Tax Box
Date of fixing in the courts 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
ARE1507306E9
ALLIANCE REGIONAL EDUCATIONAL, S. DE S.S.
500-05-2023- 21185 dated August 31, 2023
Central Administration of Strategic Audit
September 06 2023
September 07 2023
2
CWO170921KE4
COMERCIALIZADORA WORTH, S.A. DE C.V.
500-05-2023- 26018 dated October 26 2023
Central Administration of Strategic Audit
November 01 2023
November 03 2023
3
HSE1610108A8
HB SEGIND, S.A. DE C.V.
500-05-2023- 21461 dated October 25 2023
Central Administration of Strategic Audit
October 31 2023
November 01 2023
4
OCC180405GZ6
OPTIONS IN CONTINUOUS TRAINING S.C.
500-05-2023- 26031 dated October 30 2023
Central Administration of Strategic Audit
November 06 2023
November 07 2023
Section B.- Notification on the Internet page of the Tax Administration Service
R.F.C.
Name, denomination or trade name of the Taxpayer
Number and date of office global of presumption
Issuing Authority of the global presumption office
Date of notification on the internet page of the Tax Administration Service
Date on which it took effect the notification
1
ARE1507306E9
ALLIANCE REGIONAL EDUCATIONAL, S. DE S.S.
500-05-2023-21241 of date September 08, 2023
Central Administration of Strategic Audit
September 08, 2023
September 11, 2023
2
CWO170921KE4
COMERCIALIZADORA WORTH, S.A. DE C.V.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
November 10, 2023
November 13, 2023
3
HSE1610108A8
HB SEGIND, S.A. DE C.V.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
November 10, 2023
November 13, 2023
4
OCC180405GZ6
OPTIONS IN CONTINUOUS TRAINING S.C.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
November 10, 2023
November 13, 2023
Section C.- Notification in the Official Gazette of the Federations.
R.F.C.
Name, denomination or trade name of the Taxpayer
Number and date of office global of presumption
Issuing Authority of the global presumption office
Date of notification in the Official Gazette of the Federations
Date on which it took effect the notification
1
ARE1507306E9
ALLIANCE REGIONAL EDUCATIONAL, S. DE S.S.
500-05-2023-21241 of date September 08, 2023
Central Administration of Strategic Audit
December 01, 2023
December 04, 2023
2
CWO170921KE4
COMERCIALIZADORA WORTH, S.A. DE C.V.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
February 01, 2024
February 02, 2024
3
HSE1610108A8
HB SEGIND, S.A. DE C.V.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
February 01, 2024
February 02, 2024
4
OCC180405GZ6
OPTIONS IN CONTINUOUS TRAINING S.C.
500-05-2023-26097 of date November 10, 2023
Central Administration of Strategic Audit
February 01, 2024
February 02, 2024
Section D.- Notification of the OFFICE OF DEFINITIVE RESOLUTION in accordance with the fourth paragraph of article 69-B of the Federal Tax Code.
R.F.C.
Name, denomination or trade name of the Taxpayer
Number and date of resolution definitive
Authority issuer of the resolution definitive
Means of notification to the taxpayer
Court of the authority
Personal notification
Notification by Tax Box
Date of fixing in the courts 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
ARE1507306E9
ALLIANCE REGIONAL EDUCATIONAL, S. DE S.S.
500-05-2024-6716 dated March 19 2024
Central Administration of Strategic Audit
March 25 2024
March 26 2024
2
CWO170921KE4
COMERCIALIZADOR A WORTH, S.A. DE C.V.
500-05-2024- 12623 dated May 03 2024
Central Administration of Strategic Audit
May 09 2024
May 10 2024
3
HSE1610108A8
HB SEGIND, S.A. DE C.V.
500-05-2024-6870 dated April 23 2024
Central Administration of Strategic Audit
April 29 2024
April 30 2024
4
OCC180405GZ6
OPTIONS IN CONTINUOUS TRAINING S.C.
500-05-2024-6939 dated April 29 2024
Central Administration of Strategic Audit
May 06 2024
May 07 2024
Section E.- Additional data of the taxpayers.
R.F.C.
Name, denomination or trade name of the Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
1
ARE1507306E9
ALLIANCE REGIONAL EDUCATIONAL, S. DE S.S.
Miguel Hidalgo, Mexico City
Consulting services in administration
Absence of Assets, Absence of Personnel, No Material Capacity
2
CWO170921KE4
COMERCIALIZADORA WORTH, S.A. DE C.V.
San Pedro Garza García, Nuevo León
Other wholesale trade intermediaries
Absence of Assets, Absence of Personnel, No Material Capacity
3
HSE1610108A8
HB SEGIND, S.A. DE C.V.
Tolcayuca, Hidalgo
Sale in national territory of other fossil fuels
Absence of Assets, Absence of Personnel, No Material Capacity
4
OCC180405GZ6
OPTIONS IN CONTINUOUS TRAINING S.C.
Aguascalientes, Aguascalientes
Other business support services
Absence of Assets, Absence of Personnel, No Material Capacity
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