Notice 500-05-2024-18442 Communicating the Definitive Global List Under Article 69-B of the Federal Tax Code

DOF: 18/10/2024

OFFICE 500-05-2024-18442 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 says: United Mexican States.- TREASURY.- Ministry of Finance and Public Credit.

Public Service.- Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of

Strategic Taxation.

Office: 500-05-2024-18442

Subject:

The definitive global list is communicated under Article 69-B, fourth paragraph

of the Federal Tax Code.

The Central Administration of Strategic Taxation, 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 Federation on December 15, 1995, reformed by Decree published in the same Official Gazette of

the Federation on June 12

of 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 with 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 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

accordance with what is established in the First Transitory Article 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 Gazette of the Federation on June 23, 2016, in force from July 23, 2016, in accordance 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 paragraphs, fourth and fifth of the

Federal Tax Code, notifies the following:

As a result of the exercise of the attributions and powers 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 cited 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 covered by such receipts.

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

as well as numeral 69 of the Regulations of said Code, issued an office

of individual presumption to each of the

taxpayers mentioned in the cited Annex 1, and in said office 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.

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 it.

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 Official Gazette of the Federation (DOF) in the terms specified in annex 1, sections B and C, of the present

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 relation with article 135 of the Federal Tax Code.

Attending to 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 statements and provide the evidence they considered pertinent to

disprove the facts made known through the cited 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 disprove 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 definitive individual resolution, as well as to the publication of their names, denominations or trade names in the list

of taxpayers who did not disprove the facts made known and therefore, would be in definitive form in the situation to which it refers

the first paragraph of the cited article 69-B of the Federal Tax Code.

Once the term indicated in the previous paragraph has passed, 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 cited legal provision,

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

in order to disprove the facts made known 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 evidence

provided by those taxpayers the referred authorities considered that those taxpayers did not disprove the facts that they

were imputed in the individual offices of presumption already indicated, the same resolved what was appropriate and proceeded to the issuance of

definitive resolutions in which the reasons, motives and grounds were indicated for why they did not disprove 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 under no circumstances will the list be published before the thirty business days following the notification of the resolution and that, at the date it has

passed said term since the notification of the resolution and, in addition, the cited 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 Resolutive Third contained in the cited definitive resolutions, this Central Administration of Strategic Taxation,

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 disprove 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, for the reasons and grounds indicated in the definitive resolutions notified to each of them,

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 Federation, to effect, with general effects, that the fiscal receipts issued by said taxpayers do not produce nor produced any fiscal effect, such as it declares the fifth paragraph of article 69-B of the Federal Tax Code; the

above, since it is of public interest to stop the billing of non-existent operations, as well as for society to know

who are those taxpayers who carry out this type of operations.

Sincerely.

Mexico City, August 28, 2024. - In substitution for the absence of the Central Administrator of Strategic Taxation, of the

Coordinator of Strategic Taxation, of the Administrator of Strategic Taxation " 1 ", " 2 ", " 3 ", " 4 ", " 5 " and " 6 ", based on the

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.

Annex 1 of office number 500-05-2024-18442 dated August 28, 2024, corresponding to taxpayers who DID provide

arguments and/or evidence, but DID NOT disprove the reason for which they were notified of the presumption office, updating

DEFINITIVELY

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

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

Authority

issuer of the office

individual of

presumption

Means of notification to the taxpayer

Authority's public notice

Personal notification

Notification by

Tax Box

Date of posting on

the authority's public notice

Date on which

the notification took effect

Date of

notification

Date on which

the notification took effect

Date of

notification

Date on which

the notification took effect

1

CGA2101224B5

COMERCIALIZADORA

GADALOGA, S.A. DE C.V.

500-05-2023-26170 of

date December 07,

2023

Central Administration of

Strategic Taxation

December 07,

2023

December 08,

2023

2

IPN191016KPA

INTEGRACION DEL

PERSONAL A NUEVAS

PROPUESTAS, S.C.

900-04-05-00-00-2023-328

of date December 06,

2023

General Administration of

Large

Taxpayers

December 12,

2023

December 13,

2023

3

VID150310IE6

VERSATILIDAD PARA LAS

IDEAS, S.C.

500-05-2024-2070 of date

January 08,

2024

Central Administration of

Strategic Taxation

January 12,

2024

January 15,

2024

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 global office

of presumption

Issuing Authority

of the office

global

of presumption

Date of notification on the

internet page of the Service

of Tax Administration

Date on which

the notification took effect

1

CGA2101224B5

COMERCIALIZADORA GADALOGA,

S.A. DE C.V.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

January 17,

2024

January 18,

2024

2

IPN191016KPA

INTEGRACION DEL PERSONAL A

NUEVAS PROPUESTAS, S.C.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

January 17,

2024

January 18,

2024

3

VID150310IE6

VERSATILIDAD PARA

LAS IDEAS, S.C.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

January 17,

2024

January 18,

2024

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

R.F.C.

Name, denomination or trade name

of the Taxpayer

Number and date of global office

of presumption

Issuing Authority of the office

global of presumption

Date of notification in the

Official Gazette of the Federation

Date on which

the notification took effect

1

CGA2101224B5

COMERCIALIZADORA GADALOGA,

S.A. DE C.V.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

February 23,

2024

February 26,

2024

2

IPN191016KPA

INTEGRACION DEL PERSONAL A

NUEVAS PROPUESTAS, S.C.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

February 23,

2024

February 26,

2024

3

VID150310IE6

VERSATILIDAD PARA LAS IDEAS, S.C.

500-05-2024-6487 of date January 17,

2024

Central Administration of

Strategic Taxation

February 23,

2024

February 26,

2024

Section D.- Notification of the definitive RESOLUTION office 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

definitive resolution

Issuing Authority

of the resolution

definitive

Means of notification to the taxpayer

Authority's public notice

Personal notification

Notification by Tax Box

Date of posting on the

authority's public notice

Date on which

the notification took effect

Date of

notification

Date on which

the notification took effect

Date of

notification

Date on which

the notification took effect

1

CGA2101224B5

COMERCIALIZADORA

GADALOGA, S.A. DE C.V.

500-05-2024-12705 of

date May 29,

2024

Central Administration of

Strategic Taxation

June 04,

2024

June 05,

2024

2

IPN191016KPA

INTEGRACION DEL

PERSONAL

A NUEVAS

PROPUESTAS, S.C.

900-04-05-00-00-2024-197

of date May 31,

2024

General Administration of

Large

Taxpayers

June 06,

2024

June 07,

2024

3

VID150310IE6

VERSATILIDAD PARA LAS

IDEAS, S.C.

500-05-2024-12706 of

date May 27,

2024

Central Administration of

Strategic Taxation

May 31,

2024

June 03,

2024

Section E.- Additional data of the taxpayers.

R.F.C.

Name, denomination or trade name of the

Taxpayer

Tax Address

Predominant Activity

Reason for the Procedure

1

CGA2101224B5

COMERCIALIZADORA GADALOGA, S.A. DE C.V.

Guadalajara, Jalisco

Retail trade in grocery stores,

delicatessens and miscellaneous.

Absence of Assets, Absence of

Personnel, No Material Capacity

2

IPN191016KPA

INTEGRACION DEL PERSONAL A NUEVAS

PROPUESTAS, S.C.

Leon, Guanajuato

Consulting services in

administration.

Absence of Assets, Absence of

Personnel, Lack of Infrastructure

3

VID150310IE6

VERSATILIDAD PARA LAS IDEAS, S.C.

Cuauhtémoc, Mexico City.

Consulting services in

administration.

Absence of Assets, Absence of

Personnel, No Material Capacity

---

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