2024-08-09 | DOF 5735616Added
The SAT notifies 23 taxpayers that they are presumed to have issued fiscal receipts without having the assets, personnel, infrastructure, or material capacity to provide the services or produce the goods covered by those receipts, pursuant to Article 69-B of the Federal Tax Code. These taxpayers have 15 business days from the date the last notification takes effect to submit a written statement and supporting documentation to the issuing authority to rebut the presumption. If the facts are not rebutted, the authorities will issue a resolution and publish the taxpayers' names in the SAT website and the Official Gazette.
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DOF: 09/08/2024
OFFICE 500-05-2024-13073 through which the global list of taxpayers presumed to fall under the circumstance provided for in the first paragraph of Article 69-B of the Federal Tax Code is communicated.
At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- TREASURY.- Ministry of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit
Office: 500-05-2024-13073
Subject:
The global list of taxpayers presumed to fall under the circumstance provided for in Article 69-B, first paragraph of the Federal Tax Code is communicated.
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, first paragraphs, section B, fraction III, subsection e), and second, 5, first paragraph, 13, fraction VI, 23, section E, fraction I, in relation to 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 by 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 Customs Agency 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 powers 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, first and second paragraphs of the Federal Tax Code, notifies the following:
As a result of the exercise of the powers and faculties indicated in article 69-B, first and second paragraphs 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.
As a consequence of the above, the aforementioned authorities placed the taxpayers in the presumption circumstance provided for in the first paragraph of article 69-B of the Federal Tax Code, by which reason they notified each of them the individual presumption office, in which the particular facts for which the referred presumption was considered appropriate were detailed.
For this reason, and in support of the authorities issuing the aforementioned presumption offices, based on the second paragraph of article 69-B of the Federal Tax Code, it is informed to the taxpayers mentioned in the aforementioned Annex 1 of this office, that they are in the circumstance provided for in the first paragraph of article 69-B of the Federal Tax Code, this is made known to them with the object that they can manifest before the tax authority that notified them the individual office what is convenient for their right and provide, before said authorities, the documentation and information that they consider pertinent to disprove the facts that led the authority to notify them.
Therefore, it is indicated that in accordance with what is established by article 69-B, second paragraph, of the Federal Tax Code, each of the taxpayers mentioned in the aforementioned Annex 1 of this office will have a period of 15 business days, counted from the date the last of the notifications takes effect, according to the precedence established in article 69, first paragraph of the Regulations of the Federal Tax Code, in correlation with article 135 of the Federal Tax Code, in order to present directly before the offices of the authorities issuing the individual office indicated in the Annex 1 of this office, a free written document in original and two copies, signed by the taxpayer or their legal representative in accordance with article 19 of said Code, through which they manifest what is convenient for their right, attaching to said written document the documentation and information they consider pertinent to disprove the facts detailed in the aforementioned individual office.
The documentation and information they present through the aforementioned written document must comply with the requirements established in articles 18, 18-A and 19 of the Federal Tax Code.
Likewise, they are warned that if the granted period expires without providing the evidence, the documentation and respective information; or well, in case of providing them, once admitted and valued, the facts indicated in the individual office mentioned in the third paragraph of this office are not rebutted, the procedure will proceed in accordance with what is provided for in the fourth paragraph of article 69-B of the Federal Tax Code, in which case the resolution will be notified and the name, denomination or trade name will be published in the list of taxpayers who have not rebutted the facts imputed to them and, therefore, are definitively in the situation referred to in the first paragraph of article 69-B, list which for this purpose will be disseminated on the internet page of the Tax Administration Service, and published in the Official Gazette of the Federations; the above, since it is in the public interest to stop the billing of nonexistent operations and that society knows who are those taxpayers who carry out this type of operations.
Respectfully.
Mexico City, July 08, 2024. - Central Administrator of Strategic Audit, L.C. Rubén Martín López Rodríguez.- Signature.
Subject:
Annex 1 of office number 500-05-2024-13073 dated July 08, 2024, issued by the L.C. Rubén Martín López Rodríguez, Central Administrator of Strategic Audit, of the General Administration of Federal Fiscal Audit, in which, in compliance with what is established in article 69-B, second paragraph of the Federal Tax Code, it is notified to the taxpayers mentioned in this annex, that they fall under the circumstance of presumption provided for in the first paragraph of the aforementioned article 69-B of the Federal Tax Code of the Federation.
Below, in the following table, the taxpayers referred to in office number 500-05-2024-13073 dated July 08, 2024 are listed, indicating the date on which the individual office of presumption was notified.
| R.F.C. | Name, denomination or trade name of the Taxpayer | Number and date of individual presumption office | Issuing authority of the individual presumption office | Notification means to the taxpayer |
|---|---|---|---|---|
| Tax Authority Bulletin Boards | ||||
| Date of posting on the<br>Tax Authority Bulletin Boards | ||||
| 1 | ACA140130TH4<br>AIR CAP, S.A. DE C.V. | 500-74-03-02-01-2024-10816 dated June 18, 2024 | Disaggregated Administration of Federal Fiscal Audit of Federal District "4" | June 24, 2024 |
| 2 | ASL200723P24<br>ASESORIA Y SERVICIOS LERVIZA, S.A. DE C.V. | 500-51-00-01-01-2024-39260 dated June 27, 2024 | Disaggregated Administration of Fiscal Audit of Sinaloa "1" | July 03, 2024 |
| 3 | ATE200528C96<br>ANDROSA TECHNOLOGY, S.A. DE C.V. | 500-05-2024-12728 dated June 06, 2024 | Central Administration of Strategic Audit | June 12, 2024 |
| 4 | BEMF900803CT6<br>BERNAL MORALES JOSE FRANCISCO | 500-42-00-05-02-2024-02974 dated June 06, 2024 | Disaggregated Administration of Federal Fiscal Audit of Nuevo León "2" | June 12, 2024 |
| 5 | BSE190925CF6<br>BRECTON SERVICIOS, S.A. DE C.V. | 500-05-2024-12729 dated June 11, 2024 | Central Administration of Strategic Audit | June 17, 2024 |
| 6 | CAM120703914<br>CAMPORTADOR, S.P.R. DE R.L. DE C.V. | 500-05-2024-12804 dated June 19, 2024 | Central Administration of Strategic Audit | June 25, 2024 |
| 7 | CEK210703AHA<br>CONSTRUCCIONES EKT, S.A. DE C.V. | 500-05-2024-12805 dated June 19, 2024 | Central Administration of Strategic Audit | June 25, 2024 |
| 8 | CLM2102199V8<br>COMERCIALIZADORA LAPICINUM DE MEXICO, S.A. DE C.V. | 500-42-00-05-03-2024-03247 dated June 25, 2024 | Disaggregated Administration of Federal Fiscal Audit of Nuevo León "2" | July 01, 2024 |
| 9 | CSR1902281IA<br>CONSTRUCCION Y SOLUCIONES RASTEX, S.A. DE C.V. | 500-05-2024-12817 dated June 25, 2024 | Central Administration of Strategic Audit | July 02, 2024 |
| 10 | DHR2105188N9<br>DISTRIBUIDORA DE HERRAMIENTAS REDY, S. DE R.L. DE C.V. | 500-05-2024-12730 dated June 11, 2024 | Central Administration of Strategic Audit | June 13, 2024 |
| 11 | EIN2105186Q1<br>EDUFAGA INDUSTRIALES, S. DE R.L. DE C.V. | 500-05-2024-12731 dated June 19, 2024 | Central Administration of Strategic Audit | June 24, 2024 |
| 12 | FLO2002139P8<br>FLOMEDIC, S.A. DE C.V. | 500-05-2024-12816 dated June 25, 2024 | Central Administration of Strategic Audit | July 02, 2024 |
| 13 | HELA8306195L7<br>HERNANDEZ LOPEZ ALMA VERONICA | 500-08-00-03-00-2024-098 dated June 18, 2024 | Disaggregated Administration of Federal Fiscal Audit of Aguascalientes "1" | June 24, 2024 |
| 14 | LORL950211LG3<br>LOPEZ RETA LUIS RODRIGO | 500-42-00-05-01-2024-02986 dated June 06, 2024 | Disaggregated Administration of Federal Fiscal Audit of Nuevo León "2" | June 12, 2024 |
| 15 | MAR210720IJ4<br>MARKSHOP, S.A. DE C.V. | 500-05-2024-12738 dated June 19, 2024 | Central Administration of Strategic Audit | June 25, 2024 |
| 16 | NST190214E24<br>NOVOSEN SERVICIOS TECNICOS DE MEXICO, S.A. DE C.V. | 500-42-00-05-02-2024-03176 dated June 19, 2024 | Disaggregated Administration of Federal Fiscal Audit of Nuevo León "2" | June 25, 2024 |
| 17 | OQF2105272F6<br>OPERADORA QFRT, S. DE R.L. DE C.V. | 500-05-2024-12818 dated June 25, 2024 | Central Administration of Strategic Audit | June 28, 2024 |
| 18 | PCA220103FB0<br>PROSAP CAPITAL, S.A. DE C.V. | 500-05-2024-12739 dated June 19, 2024 | Central Administration of Strategic Audit | June 25, 2024 |
| 19 | PHS870919GG0<br>PRODUCTOS HIGIÉNICOS SOLAR, S.A. DE C.V. | 500-18-00-05-02-2024-1774 dated June 28, 2024 | Disaggregated Administration of Federal Fiscal Audit of Colima "1" | July 01, 2024 |
| 20 | REC210518UA1<br>RECJUM, S. DE R.L. DE C.V. | 500-05-2024-12740 dated June 19, 2024 | Central Administration of Strategic Audit | June 25, 2024 |
| 21 | SAGE830122U16<br>SAAVEDRA GONZALEZ ERICK | 500-42-00-05-03-2024-02980 dated June 06, 2024 | Disaggregated Administration of Federal Fiscal Audit of Nuevo León "2" | June 12, 2024 |
| 22 | SIS201106HL9<br>SOPORTE EN INDUSTRIA SIERRA NORTE, S.A. DE C.V. | 500-05-2024-12806 dated June 25, 2024 | Central Administration of Strategic Audit | June 26, 2024 |
| 23 | TLO190808754<br>TREMBAR LOGISTICON, S.A. DE C.V. | 500-04-00-00-00-2024-14792 dated June 04, 2024 | Central Administration of Verification and Evaluation of Federal Entities in Matters of Fiscal Coordination | June 10, 2024 |
Additional data of the taxpayers.
| R.F.C. | Name, denomination or trade name of the Taxpayer | Fiscal Address | Preponderant Activity | Reason for the Procedure | |
|---|---|---|---|---|---|
| 1 | ACA140130TH4 | AIR CAP, S.A. DE C.V. | Benito Juárez, Mexico City | Other Services related to air transport. | Absence of Assets, Absence of Personnel, No Material Capacity |
| 2 | ASL200723P24 | ASESORIA Y SERVICIOS LERVIZA, S.A. DE C.V. | Miguel Hidalgo, Mexico City | Wholesale trade of containers, paper and cardboard; wholesale trade of cement, brick and gravel; other repair and maintenance services of automobiles and trucks; consulting services in administration; other civil engineering constructions or heavy work | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
| 3 | ATE200528C96 | ANDROSA TECHNOLOGY, S.A. DE C.V. | San Pedro Garza García, Nuevo León | Software editing, except through the internet | Absence of Assets, Absence of Personnel, No Material Capacity |
| 4 | BEMF900803CT6 | BERNAL MORALES JOSE FRANCISCO | Apodaca, Nuevo León | Consulting services in administration | Absence of Assets, Lack of Infrastructure, No Material Capacity |
| 5 | BSE190925CF6 | BRECTON SERVICIOS, S.A. DE C.V. | Torreón, Coahuila de Zaragoza | Accounting and auditing services | Absence of Assets, Absence of Personnel, No Material Capacity |
| 6 | CAM120703914 | CAMPORTADOR, S.P.R. DE R.L. DE C.V. | Guadalajara, Jalisco | Wholesale trade of fresh fruits and vegetables | Absence of Assets, Absence of Personnel, No Material Capacity |
| 7 | CEK210703AHA | CONSTRUCCIONES EKT, S.A. DE C.V. | Salvador Alvarado, Sinaloa | Construction of urbanization works | Absence of Assets, Absence of Personnel, No Material Capacity |
| 8 | CLM2102199V8 | COMERCIALIZADORA LAPICINUM DE MEXICO, S.A. DE C.V. | San Nicolás de los Garza, Nuevo León | Other Wholesale Trade Intermediaries | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
| 9 | CSR1902281IA | CONSTRUCCION Y SOLUCIONES RASTEX, S.A. DE C.V. | Monterrey, Nuevo León | Other finishing works in buildings | Absence of Assets, Absence of Personnel, No Material Capacity |
| 10 | DHR2105188N9 | DISTRIBUIDORA DE HERRAMIENTAS REDY, S. DE R.L. DE C.V. | Torreón, Coahuila de Zaragoza | Wholesale sale by commission and consignment | Absence of Assets, Absence of Personnel, No Material Capacity |
| 11 | EIN2105186Q1 | EDUFAGA INDUSTRIALES, S. DE R.L. DE C.V. | Torreón, Coahuila de Zaragoza | Repair and maintenance of industrial machinery and equipment | Absence of Assets, Absence of Personnel, No Material Capacity |
| 12 | FLO2002139P8 | FLOMEDIC, S.A. DE C.V. | Guadalajara, Jalisco | Wholesale trade of pharmaceutical products | Absence of Assets, Absence of Personnel, No Material Capacity |
| 13 | HELA8306195L7 | HERNANDEZ LOPEZ ALMA VERONICA | Aguascalientes, Aguascalientes | Wholesale trade of cement, brick and gravel | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
| 14 | LORL950211LG3 | LOPEZ RETA LUIS RODRIGO | Apodaca, Nuevo León | Other Business Support Services | Absence of Assets, Lack of Infrastructure, No Material Capacity |
| 15 | MAR210720IJ4 | MARKSHOP, S.A. DE C.V. | Torreón, Coahuila de Zaragoza | Wholesale trade of other general use machinery and equipment | Absence of Assets, Absence of Personnel, No Material Capacity |
| 16 | NST190214E24 | NOVOSEN SERVICIOS TECNICOS DE MEXICO, S.A. DE C.V. | Monterrey, Nuevo León | Wholesale trade of wood | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
| 17 | OQF2105272F6 | OPERADORA QFRT, S. DE R.L. DE C.V. | Torreón, Coahuila de Zaragoza. | Repair and maintenance of other electronic equipment and precision equipment | Absence of Assets, Absence of Personnel, No Material Capacity |
| 18 | PCA220103FB0 | PROSAP CAPITAL, S.A. DE C.V. | Torreón, Coahuila de Zaragoza. | Wholesale trade of perfumery items | Absence of Assets, Absence of Personnel, No Material Capacity |
| 19 | PHS870919GG0 | PRODUCTOS HIGIÉNICOS SOLAR, S.A. DE C.V. | Guadalajara, Jalisco | Manufacturing of soaps, cleaners and dentifrices | Absence of Assets, Absence of Personnel, No Material Capacity |
| 20 | REC210518UA1 | RECJUM, S. DE R.L. DE C.V. | Torreón, Coahuila de Zaragoza. | Consulting services in administration | Absence of Assets, Absence of Personnel, No Material Capacity |
| 21 | SAGE830122U16 | SAAVEDRA GONZALEZ ERICK | San Nicolás de los Garza, Nuevo León | Other business support services | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
| 22 | SIS201106HL9 | SOPORTE EN INDUSTRIA SIERRA NORTE, S.A. DE C.V. | San Pedro Garza Garcia, Nuevo León | Wholesale trade of machinery and equipment for other services and for commercial activities | Absence of Assets, Absence of Personnel, No Material Capacity |
| 23 | TLO190808754 | TREMBAR LOGISTICON, S.A. DE C.V. | Torreón, Coahuila de Zaragoza. | Wholesale trade of machinery and equipment for construction and mining | Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity |
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