Regulatory Alerts2024-11-01 | DOF 5742113Added
Notice 500-05-2024-18376 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code
The Strategic Taxation Administration of the SAT communicates that the tax proceedings against twelve specific taxpayers under Article 69-B of the Federal Tax Code (effective until July 24, 2018) have been rendered without effect due to favorable judicial rulings. These rulings declared null and void the definitive resolutions issued against these entities, which had previously been listed for promoting defense mechanisms against presumption notices regarding the non-existence of operations. The document lists the taxpayers, their tax ID numbers, the specific nullified resolutions, and the courts that issued the decisions.
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DOF: 01/11/2024
OFFICE 500-05-2024-18376 communicating the list of taxpayers who promoted some means of defense against the presumption office referred to in the first paragraph of Article 69-B of the Federal Tax Code, valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.
At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- TREASURY.- Ministry of
Treasury and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit
Central Administration of Strategic Taxation.
Office: 500-05-2024-18376
Subject: Communication of the list of taxpayers who
promoted some means of defense against the office
of presumption referred to in Article 69-B first
paragraph of the CFF, valid until July 24, 2018, or in
against the resolution referred to in the third paragraph
of the aforementioned article, and once resolved, the
jurisdictional or administrative body left unsubstantiated
the referred act.
This Central Administration of Strategic Taxation, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is established by 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 Journal of the Federation
december 15, 1995, reformed by Decree published in the same Official Journal of the Federation 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 first paragraphs, fraction VIII, and
last, numeral 5, of the Internal Regulations of the Tax Administration Service, published in the Official Journal
of the Federation on August 24, 2015, effective from November 22, 2015,
in accordance with what is established in the first paragraph of Article First Transitory of said Regulations, and
reformed by Decree by which various provisions of the Internal Regulations of the
Ministry of Treasury and Public Credit and of the Internal Regulations of the Service
of Tax Administration, and by which the Internal Regulations of the National Agency of Customs
of Mexico, published in the same official organ on December 21, 2021, effective from January 01
2022, in accordance with what is established in Article First Transitory of said Decree; Article
Third, 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 Journal of the Federation on June 23
2016, effective from July 23, 2016, in accordance with what is established in article
Transitory First of said Agreement; in articles 33, last paragraph, 63 and 69-B, paragraphs first and
second of the Federal Tax Code valid until July 24, 2018, in relation to article
Second Transitory of the "DECRETE by which article 69-B of the Federal Tax Code is reformed"
Federación", published in the Official Journal of the Federation on June 25, 2018 and Article Tenth
Transitory, fraction IV, of the Fiscal Miscellany Resolution for 2024, published in the Official Journal of the
Federation on December 29, 2023,
communicates to you the following:
That to the taxpayers listed below, at that time, they were notified of an Office of
Presumption of non-existence of operations backed by certain fiscal receipts that
they issued, this in accordance with the first and second paragraphs of article 69-B of the Federal Tax Code
Federación, valid until July 24, 2018, in relation to article 69 of its Regulations.
Following the procedure provided for in the aforementioned article 69-B of the Federal Tax Code, valid
until July 24, 2018, and in terms of the third paragraph of the aforementioned article, to the taxpayers of
reference they were notified of the definitive resolution as indicated below:
Notification to the taxpayer of the OFFICE OF THE DEFINITIVE RESOLUTION.
No.
R.F.C.
Name, denomination or
social reason of the
Taxpayer
Number and date of
office of resolution
definitive
Means of notification to the taxpayer
Tax Box
Authority's court
Personal Notification
Date on
which it was
notified in
Tax
Box
Date on which
the notification
took effect
Date of
fixation in the
court of the
Fiscal
Authority
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
01
AIC0906256F6
ADMINISTRACION DE
INFRAESTRUCTURA DE
CANCUN, S.A. DE C.V.
500-04-00-00-00-
2020-12214 dated
March 24, 2020
March 30
2020
March 31, 2020
02
BULJ840808A99
BUSTAMANTE LOPEZ
JESUS ANDRES
500-09-00-06-01-
2017-04728 dated
October 23,
2017
November 09
2017
December 05
2017
03
CAGV651208P57
CASTAÑEDA GARCIA
VICTOR MANUEL
500-31-00-04-01-
2017-3084 dated July 31
2017
August 04
2017
August 07, 2017
04
CGM1306078U6
CONSTRUCTORA GGCL
MUNDIAL, S.A. DE C.V.
500-04-00-00-00-
2018-30791 dated
November 07, 2018
January 09, 2019
February 01
2019
05
CIT131211GF3
COORDINACION
INTELIGENTE TYT, S.A.
DE C.V.
500-04-00-00-00-
2018-13226 dated
May 11, 2018
May 17
2018
May 18, 2018
06
DCP141030LI8
COMERCIALIZADORA Y
DISTRIBUIDORA PRISMA,
S.A. DE C.V.
500-31-00-06-03-
2017-23828 dated
August 21, 2017
September 11
2017
October 04
2017
07
ENC120704M30
ENCADI, S.C.
500-70-00-04-00-
2017-08607 dated
August 25, 2017
August 30, 2017
September 22
2017
08
INM1209131C5
INMIPRO, S.A. DE C.V.
500-12-00-04-02-
2018-08599 dated
October 31, 2018
November 08
2018
November 09
2018
09
MCO101210R77
MVG CONSULTORES,
S.C.
500-30-00-08-01-
2018-02819 dated
April 20, 2018
April 24, 2018
April 25, 2018
10
RAOR681225AJ2
RAMIREZ OCHOA ROSA
VELIA
500-47-00-02-00-
2023-5754 dated
September 28, 2023
October 04
2023
October 05, 2023
11
TAC090816EJ9
TRANSFORMACION
ARQUITECTONICA
CORPORATIVA, S.A. DE
C.V.
500-04-00-00-00-
2020-25273 dated
October 16, 2020
October 22
2022
October 23, 2020
12
USS070829N45
CODI SOLUCIONES, S.A.
DE C.V., PREVIOUSLY U
SOLUTION SERVICIOS
TECNOLOGICOS Y
ADMINISTRATIVOS, S.A.
DE C.V.
900-04-03-00-00-
2020-13974 dated
November 18, 2020
November 24
2020
November 25
2020
Additional data of the taxpayers.
No.
R.F.C.
Name, denomination or social
reason of the Taxpayer
Fiscal Address
Preponderant Activity
Reason for the Procedure
01
AIC0906256F6
ADMINISTRACION DE
INFRAESTRUCTURA DE CANCUN,
S.A. DE C.V.
MÉRIDA, YUCATÁN
OTHER INSTALLATIONS AND EQUIPMENT IN
CONSTRUCTIONS
Absence of assets
Absence of
personnel
02
BULJ840808A99
BUSTAMANTE LOPEZ JESUS
ANDRES
SAN LUIS RÍO COLORADO,
SONORA
SALE OF SAND, GRAVEL, STONE,
EARTH AND OTHER MOVABLE GOODS
FROM THE GROUND
Absence of assets
Absence of
personnel
03
CAGV651208P57
CASTAÑEDA GARCIA VICTOR
MANUEL
MIGUEL HIDALGO, MEXICO CITY
CONSULTING SERVICES IN
ADMINISTRATION
Absence of assets
Absence of
personnel
Lack of Infrastructure
04
CGM1306078U6
CONSTRUCTORA GGCL MUNDIAL,
S.A. DE C.V.
GUADALUPE, NUEVO LEÓN
OTHER SPECIALIZED WORKS FOR THE
CONSTRUCTION
Absence of assets
Absence of
personnel
Without material capacity
05
CIT131211GF3
COORDINACION INTELIGENTE TYT,
S.A. DE C.V.
TUXTLA GUTIÉRREZ, CHIAPAS
ACCOUNTING AND AUDITING SERVICES
Absence of assets
Absence of
personnel
Without material capacity
Lack of Infrastructure
06
DCP141030LI8
COMERCIALIZADORA Y
DISTRIBUIDORA PRISMA, S.A. DE
C.V.
GUADALAJARA, JALISCO
OTHER WHOLESALE COMMERCE INTERMEDIARIES, AND WHOLESALE COMMERCE
OF DISTILLED BEVERAGES FROM AGAVE.
Lack of Infrastructure
07
ENC120704M30
ENCADI, S.C.
ZAPOPAN, JALISCO
OTHER WHOLESALE COMMERCE INTERMEDIARIES
Absence of assets
Absence of
personnel
Without material capacity
Lack of Infrastructure
08
INM1209131C5
INMIPRO, S.A. DE C.V.
LA PAZ, BAJA CALIFORNIA
SUR
OTHER CIVIL ENGINEERING CONSTRUCTIONS OR HEAVY WORK
Absence of assets
Absence of
personnel
Without material capacity
Lack of Infrastructure
09
MCO101210R77
MVG CONSULTORES, S.C.
GUADALAJARA, JALISCO
CONSULTING SERVICES IN
ADMINISTRATION
Absence of assets
Absence of
personnel
10
RAOR681225AJ2
RAMIREZ OCHOA ROSA VELIA
QUERÉTARO, QUERÉTARO
WHOLESALE TRADE OF METAL WASTE.
Absence of assets
Absence of
personnel
11
TAC090816EJ9
TRANSFORMACION
ARQUITECTONICA CORPORATIVA,
S.A. DE C.V.
MÉRIDA, YUCATÁN
OTHER INSTALLATIONS AND EQUIPMENT IN
CONSTRUCTIONS
Absence of assets
Absence of
personnel
Without material capacity
Lack of Infrastructure
12
USS070829N45
CODI SOLUCIONES, S.A. DE C.V.,
PREVIOUSLY U SOLUTION SERVICIOS
TECNOLOGICOS Y
ADMINISTRATIVOS, S.A. DE C.V.
EL LLANO, AGUASCALIENTES
WHOLESALE TRADE OF MACHINERY AND
AGRICULTURAL, FORESTRY AND FISHING EQUIPMENT
Absence of assets
Absence of
personnel
Therefore, the names or social reason of the taxpayers to whom the aforementioned
resolutions were notified were added to the list referred to in the third paragraph of Article 69-B of the Federal Tax Code
Federación, valid until July 24, 2018, which was published in the Official Journal of the
Federation, as indicated below:
No.
R.F.C.
Name, denomination or social reason of the Taxpayer
Number and date of office contained in List
Global Definitive
Date of publication in the Official Journal
of the Federation
01
AIC0906256F6
ADMINISTRACION DE INFRAESTRUCTURA DE CANCUN,
S.A. DE C.V.
500-05-2020-13611 dated May 28, 2020
July 01, 2020
02
BULJ840808A99
BUSTAMANTE LOPEZ JESUS ANDRES
500-05-2018-8116 dated February 27, 2018
March 13, 2018
03
CAGV651208P57
CASTAÑEDA GARCIA VICTOR MANUEL
500-05-2021-10802 dated March 25, 2021
April 08, 2021
04
CGM1306078U6
CONSTRUCTORA GGCL MUNDIAL, S.A. DE C.V.
500-05-2019-22246 dated July 11, 2019
August 26, 2019
05
CIT131211GF3
COORDINACION INTELIGENTE TYT, S.A. DE C.V.
500-05-2018-22861 dated August 27, 2018
October 08, 2018
06
DCP141030LI8
COMERCIALIZADORA Y DISTRIBUIDORA PRISMA,
S.A.
DE C.V.
500-05-2017-38830 dated December 22, 2017
January 29, 2018
07
ENC120704M30
ENCADI, S.C.
500-05-2018-572 dated January 26, 2018
February 26, 2018
08
INM1209131C5
INMIPRO, S.A. DE C.V.
500-05-2019-18068 dated May 24, 2019
July 01, 2019
09
MCO101210R77
MVG CONSULTORES, S.C.
500-05-2018-22825 dated August 17, 2018
October 09, 2018
10
RAOR681225AJ2
RAMIREZ OCHOA ROSA VELIA
This taxpayer was not published in the definitive global lists.
11
TAC090816EJ9
TRANSFORMACION ARQUITECTONICA CORPORATIVA,
S.A. DE C.V.
500-05-2021-5060 dated February 09, 2021
February 24, 2021
12
USS070829N45
CODI SOLUCIONES, S.A. DE C.V., PREVIOUSLY U SOLUTION
SERVICIOS TECNOLOGICOS Y ADMINISTRATIVOS, S.A.
DE C.V.
500-05-2017-32186 dated September 26, 2017
October 26, 2017
Disagreeing with the individual presumption office or definitive resolution office, they filed means of
defense of which the following resolution or sentence was concluded:
No.
R.F.C.
Name, denomination or social
reason of the Taxpayer
Means of defense
Date of the
Resolution or
firm sentence
Authority that resolved
Sense and/or effect of the resolution or sentence
firm
01
AIC0906256F6
ADMINISTRACION DE
INFRAESTRUCTURA DE
CANCUN, S.A. DE C.V.
Nullity Trial
1177/20-16-01-3
February 20, 2023
Peninsular Regional Chamber, of the
Federal Tribunal of Administrative
Justice
The nullity of the challenged resolution 600- 69-2020-01769 dated July 09, 2020, issued
by the Decentralized Legal Administration of
Yucatán "1", regarding the Online Administrative Revocation Appeal RRL2020003960, as well as,
the originally appealed 500-04-00-00-00-2020-12214
of March 24, 2020, issued by the Administration
Central of Verification and Evaluation of Entities
Federative in Fiscal Coordination Matters.
02
BULJ840808A99
BUSTAMANTE LOPEZ JESUS
ANDRES
Nullity Trial
477/20-01-02-6
February 03, 2023
Second Regional Chamber
of the Northwest I, of the
Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500-09-00-06-01-2017-04728 dated October 23
2017, issued by the Administration
Decentralized of Fiscal Audit of Baja
California
"1".
03
CAGV651208P57
CASTAÑEDA GARCIA VICTOR
MANUEL
Nullity Trial
1367/22-08-01-8
April 03, 2023
Regional Chamber of Center
I, of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500- 31-00-04-01-2017-3084 dated July 31, 2017,
issued by the Decentralized Administration of
Fiscal Audit of Jalisco "2".
04
CGM1306078U6
CONSTRUCTORA GGCL
MUNDIAL, S.A. DE C.V.
Nullity Trial
2001/19-06-03-7
April 19, 2024
Third Regional Chamber
of the Northeast of the Tribunal
Federal of Administrative
Justice
The nullity of the challenged resolution 500-04-00-00-00-2018-30791 dated November 07
2018, issued by the Administration
Central of Verification and Evaluation of Entities
Federative in Fiscal Coordination Matters.
05
CIT131211GF3
COORDINACION INTELIGENTE
TYT, S.A. DE C.V.
Nullity Trial
246/21-19-01-5-OT
August 24, 2022
Regional Chamber of
Chiapas of the Tribunal
Federal of Administrative
Justice
The nullity of the challenged resolution 600- 19-00-00-00-2018-3141 dated August 27, 2018,
issued by the Decentralized Legal Administration
of Chiapas "1", regarding the Online Administrative Revocation Appeal
RRL2018005486, as well as,
the originally appealed 500-04-00-00-00-00-2018-
13226 of May 11, 2018, issued by the
Central Administration of Verification and Evaluation of
Federative Entities in Fiscal Coordination Matters.
06
DCP141030LI8
COMERCIALIZADORA Y
DISTRIBUIDORA PRISMA, S.A.
DE C.V.
Nullity Trial
8166/21-07-03-5
January 05, 2024
Third Regional Chamber
of the West of the
Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500- 31-00-06-03-2017-23828 dated August 21, 2017,
issued by the Decentralized Administration of
Fiscal Audit of Jalisco "2".
07
ENC120704M30
ENCADI, S.C.
Nullity Trial
4052/22-07-02-7
November 28, 2022
Second Regional Chamber
of the West of the
Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500- 70-00-04-00-2017-08607 dated August 25, 2017,
issued by the Decentralized Administration of
Fiscal Audit of Zacatecas "1".
08
INM1209131C5
INMIPRO, S.A. DE C.V.
Nullity Trial
1637/20-03-01-10
March 22, 2023
Regional Chamber of the North
Center IV and Auxiliary of the
Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 600-12-2020-000131 dated January 21
2020, issued by the Decentralized Administration
Legal of Baja California Sur "1", regarding the Appeal
Online Administrative Revocation
RRL2019000151, as well as the originally appealed
500-12-00-04-02-2018-08599 of October 31, 2018,
issued by the Decentralized Administration of
Fiscal Audit of Baja California Sur "1".
09
MCO101210R77
MVG CONSULTORES, S.C.
Nullity Trial
2139/22-07-03-5
January 05, 2024
Third Regional Chamber
of the West of the
Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500- 30-00-08-01-2018-02819 dated April 20, 2018,
issued by the Decentralized Administration of
Fiscal Audit of Jalisco "1", and the authority is condemned to fulfill the obligation referred to in
subsection d) of Rule 1.4. of the Fiscal Miscellany
Resolution for 2018, publishing the plaintiff in the list
relative.
10
RAOR681225AJ2
RAMIREZ OCHOA ROSA VELIA
Nullity Trial
1599/21-09-01-4
December 05, 2023
Regional Chamber of the Center
II, of the Federal Tribunal
of Administrative
Justice
The nullity of the challenged resolution 500-47-00-02-00-2023-5754 dated September 28,
2023, issued by the Administration
Decentralized of Fiscal Audit of Querétaro "1".
11
TAC090816EJ9
TRANSFORMACION
ARQUITECTONICA
CORPORATIVA, S.A. DE C.V.
Nullity Trial
535/21-16-01-2
September 30, 2022
Peninsular Regional Chamber
of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 600-69-2021-00573 dated February 11
2021, issued by the Decentralized Administration
Legal of Yucatán "1", as well as the originally
appealed 500-04-00-00-00-2020-25273 of October 16,
2020, issued by the Central Administration
of Verification and Evaluation of Federative Entities
in Fiscal Coordination Matters.
12
USS070829N45
CODI SOLUCIONES, S.A. DE
C.V., PREVIOUSLY U SOLUTION
SERVICIOS TECNOLOGICOS Y
ADMINISTRATIVOS, S.A. DE
C.V.
Nullity Trial
15612/21-17-05-8
February 10, 2023
Fifth Regional Chamber
Metropolitan of the
Federal Tribunal of Administrative
Justice
The nullity of the challenged resolution 900-04-03-00-00-2020-13974 dated November 18
2020, issued by the Administration
Central of Taxation to Large Taxpayers
Various.
In view of the above, it is informed that, as a consequence of the means of defense indicated
in the preceding paragraph, the procedure of Article 69-B of the Federal Tax Code valid until
July 24, 2018, followed with those taxpayers, has become ineffective.
Finally, it is informed that the fact that the aforementioned taxpayers have obtained a
favorable resolution against the presumption offices and/or definitive resolution, does not exempt them from the
responsibility they may have regarding other fiscal receipts they have issued without having the
assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or
produce, commercialize or deliver the goods that backed such receipts, for which, the powers of the
fiscal authority are reserved.
Respectfully.
Mexico City, August 09, 2024. - In substitution for the absence of the Central Administrator of
Strategic Taxation, of the Coordinator of Strategic Taxation, of the Administrator of Fiscal
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: C.P.
Nayeli Margarita Ramos Hernández, Administrator of Strategic Taxation "7".- Rubric.
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