Regulatory Alerts2024-11-29 | DOF 5744028Added
Notice 500-05-2024-18776 Communicating the Definitive Global List under Article 69-B, Paragraph Four of the Federal Tax Code
The Tax Administration Service publishes the definitive global list of eight taxpayers whose tax invoices are deemed to have no fiscal effect because they failed to rebut the presumption that they lacked the assets, personnel, infrastructure, or material capacity to provide the services or produce the goods invoiced. The affected entities are Comercializadora Lezadel, S.A. de C.V., Creative Leap, S.A. de C.V., Nestrocks, S.A. de C.V., Nextery, S.A. de C.V., Quality Products Worldwide OBM, S.A. de C.V., Sanchez Arevalo Eugenio, Servicios Corporativos Serma, S. de R.L. de C.V., and Upperprime, S.A. de C.V. This determination follows the expiration of the period granted for these taxpayers to present evidence and arguments, which were found insufficient to disprove the initial findings of fictitious operations.
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DOF: 11/29/2024
OFFICE 500-05-2024-18776 communicating the definitive global list under Article 69-B, paragraph four of the Federal Tax Code
At the margin, a logo that says: Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Audit.
Office: 500-05-2024-18776
Subject:
Definitive global list is communicated under Article 69-B, paragraph four 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 Tax Administration Service Law, published in the Official Gazette of the Federation on December 15, 1995, reformed 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 paragraph, 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, effective from November 22, 2015, in accordance 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 Agency of Customs of Mexico are issued, published in the same official organ on December 21, 2021, effective from January 1, 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 powers are delegated to the Public Servants of the Tax Administration Service, published in the Official Gazette of the Federation on June 23, 2016, effective 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, fourth and fifth 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 tax 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 individual presumption notice to each of the taxpayers mentioned in the aforementioned Annex 1, and in said notice 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 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 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 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 relation to 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 individual presumption notices the tax authorities granted each taxpayer a term of fifteen business days counted from the last of the aforementioned notifications, to make the statements and provide the evidence they considered pertinent to rebut the facts known through the aforementioned notices, warned that if after the granted term they did not provide the documentation and information and/or what they exhibited, once valued, did not rebut the facts indicated in the notices 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 publish their names, denominations or trade names in the list of taxpayers who did not rebut the facts known and therefore, would be in a definitive situation referred to in the first paragraph of the aforementioned article 69-B of the Federal Tax Code.
Once the term indicated in the previous 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 provision, presented, through the means indicated in the individual resolutions themselves, various information, documentation and arguments in order to rebut the facts 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 proofs provided by those taxpayers the aforementioned authorities considered that those taxpayers did not rebut the facts 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 fourth paragraph of article 69-B of the Federal Tax Code, states 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 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 for in article 69-B of the Federal Tax Code, that has been initiated against them; therefore, in order to give full compliance to Resolutive Third contained in the aforementioned definitive resolutions, 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 this, 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 imputed to them and therefore, are in a definitive situation referred to in the first paragraph of the aforementioned 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 tax 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 billing of non-existent operations be stopped, as well as that society knows who those taxpayers are who carry out this type of operations.
Respectfully
Mexico City, October 28, 2024. - In substitution for the absence of the Central Administrator of Strategic Audit, from the Coordinator of Strategic Audit, of the Administrator of Strategic Audit "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 Audit "7". - Rubric.
Annex 1 of office number 500-05-2024-18776 of date October 28, 2024, corresponding to taxpayers who DID provide arguments and/or proofs, but DID NOT rebut the reason for which the presumption notice was notified to them, definitively updating the situation referred to in the first paragraph of article 69-B of the Federal Tax Code
Section A.- Notification of the PRESUMPTION NOTICE in accordance with the first and second paragraphs of article 69-B of the Federal Tax Code, in relation to article 69 of its Regulations.
| R.F.C. | Name, denomination or trade name of the Taxpayer | Number and date of individual presumption notice | Issuing authority of the individual presumption notice | Notification means to the taxpayer |
|---|---|---|---|---|
| Authority's Chambers | ||||
| Date of fixing on the chambers of the Fiscal Authority | ||||
| 1 | CLE080825BP9<br>COMERCIALIZADORA LEZADEL, S.A. DE C.V. | 500-32-00-03-04-2024-2228 of date March 15, 2024 | Disaggregated Administration of Fiscal Audit of Jalisco "3" | 22 of March of 2024 |
| 2 | CLE190426UG5<br>CREATIVE LEAP, S.A. DE C.V. | 500-05-2024-6545 of date January 31, 2024 | Central Administration of Strategic Audit | 07 of February of 2024 |
| 3 | NES190517GA6<br>NESTROCK, S.A. DE C.V. | 500-05-2024-6554 of date February 01, 2024 | Central Administration of Strategic Audit | 08 of February of 2024 |
| 4 | NEX190523FV3<br>NEXTERITY, S.A. DE C.V. | 500-05-2024-6547 of date January 31, 2024 | Central Administration of Strategic Audit | 01 of February of 2024 |
| 5 | QPW160825QQ3<br>QUALITY PRODUCTS WORLWIDE OBM, S.A. DE C.V. | 500-32-00-03-04-2024-1331 of date February 15, 2024 | Disaggregated Administration of Fiscal Audit of Jalisco "3" | 21 of February of 2024 |
| 6 | SAAE840201QA0<br>SANCHEZ AREVALO EUGENIO | 500-37-00-07-02-2019-5749 of date January 21, 2019 | Disaggregated Administration of Fiscal Audit of Michoacán "1" | 23 of January of 2019 |
| 7 | SCS1804264C1<br>SERVICIOS CORPORATIVOS SERMA, S. DE R.L. DE C.V. | 500-37-00-07-02-2024-10705 of date January 17, 2024 | Disaggregated Administration of Fiscal Audit of Michoacán "1" | 23 of January of 2024 |
| 8 | UPP190508LJ7<br>UPPERPRIME, S.A. DE C.V. | 500-05-2024-6546 of date January 31, 2024 | Central Administration of Strategic Audit | 07 of February of 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 presumption notice | Issuing authority of the global presumption notice | Date of notification on the internet page of the Tax Administration Service | Date on which the notification took effect |
|---|---|---|---|---|---|
| 1 | CLE080825BP9<br>COMERCIALIZADORA LEZADEL, S.A. DE C.V. | 500-05-2024-6840 of date April 05, 2024 | Central Administration of Strategic Audit | April 05, 2024 | April 08, 2024 |
| 2 | CLE190426UG5<br>CREATIVE LEAP, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | February 09, 2024 | February 12, 2024 |
| 3 | NES190517GA6<br>NESTROCK, S.A. DE C.V. | 500-05-2024-6715 of date March 08, 2024 | Central Administration of Strategic Audit | March 08, 2024 | March 11, 2024 |
| 4 | NEX190523FV3<br>NEXTERITY, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | February 09, 2024 | February 12, 2024 |
| 5 | QPW160825QQ3<br>QUALITY PRODUCTS WORLWIDE OBM, S.A. DE C.V. | 500-05-2024-6715 of date March 08, 2024 | Central Administration of Strategic Audit | March 08, 2024 | March 11, 2024 |
| 6 | SAAE840201QA0<br>SANCHEZ AREVALO EUGENIO | 500-05-2019-7389 of date May 02, 2019 | Central Administration of Strategic Audit | May 02, 2019 | May 03, 2019 |
| 7 | SCS1804264C1<br>SERVICIOS CORPORATIVOS SERMA, S. DE R.L. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | February 09, 2024 | February 12, 2024 |
| 8 | UPP190508LJ7<br>UPPERPRIME, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | February 09, 2024 | February 12, 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 presumption notice | Issuing authority of the global presumption notice | Date of notification in the Official Gazette of the Federation | Date on which the notification took effect |
|---|---|---|---|---|---|
| 1 | CLE080825BP9<br>COMERCIALIZADORA LEZADEL, S.A. DE C.V. | 500-05-2024-6840 of date April 05, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 2 | CLE190426UG5<br>CREATIVE LEAP, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 3 | NES190517GA6<br>NESTROCK, S.A. DE C.V. | 500-05-2024-6715 of date March 08, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 4 | NEX190523FV3<br>NEXTERITY, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 5 | QPW160825QQ3<br>QUALITY PRODUCTS WORLWIDE OBM, S.A. DE C.V. | 500-05-2024-6715 of date March 08, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 6 | SAAE840201QA0<br>SANCHEZ AREVALO EUGENIO | 500-05-2019-7389 of date May 02, 2019 | Central Administration of Strategic Audit | May 23, 2019 | May 24, 2019 |
| 7 | SCS1804264C1<br>SERVICIOS CORPORATIVOS SERMA, S. DE R.L. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
| 8 | UPP190508LJ7<br>UPPERPRIME, S.A. DE C.V. | 500-05-2024-6581 of date February 09, 2024 | Central Administration of Strategic Audit | May 31, 2024 | June 03, 2024 |
Section D.- Notification of the RESOLUTION NOTICE 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 definitive resolution | Notification means to the taxpayer |
|---|---|---|---|---|
| Authority's Chambers | ||||
| Date of fixing on the chambers of the Fiscal Authority | ||||
| 1 | CLE080825BP9<br>COMERCIALIZADORA LEZADEL, S.A. DE C.V. | 500-32-00-03-04-2024-6026 of date September 02, 2024 | Disaggregated Administration of Fiscal Audit of Jalisco "3" | 06 of September of 2024 |
| 2 | CLE190426UG5<br>CREATIVE LEAP, S.A. DE C.V. | 500-05-2024-18508 of date September 04, 2024 | Central Administration of Strategic Audit | 05 of September of 2024 |
| 3 | NES190517GA6<br>NESTROCK, S.A. DE C.V. | 500-05-2024-18511 of date September 04, 2024 | Central Administration of Strategic Audit | 10 of September of 2024 |
| 4 | NEX190523FV3<br>NEXTERITY, S.A. DE C.V. | 500-05-2024-18509 of date September 04, 2024 | Central Administration of Strategic Audit | 04 of September of 2024 |
| 5 | QPW160825QQ3<br>QUALITY PRODUCTS WORLWIDE OBM, S.A. DE C.V. | 500-32-00-03-04-2024-6017 of date August 30, 2024 | Disaggregated Administration of Fiscal Audit of Jalisco "3" | 05 of September of 2024 |
| 6 | SAAE840201QA0<br>SANCHEZ AREVALO EUGENIO | // In compliance with the sentence of date December 07, 2022, issued by the Regional Chamber of the Pacific Center of the Federal Court of Administrative Justice within the Nullity Trial 1170/22-21-01-3-OT. | 500-37-00-07-02-2024-20462 of date April 16, 2024 | Disaggregated Administration of Fiscal Audit of Michoacán "1" |
| 7 | SCS1804264C1<br>SERVICIOS CORPORATIVOS SERMA, S. DE R.L. DE C.V. | 500-37-00-07-02-2024-27047 of date July 09, 2024 | Disaggregated Administration of Fiscal Audit of Michoacán "1" | 29 of July of 2024 |
| 8 | UPP190508LJ7<br>UPPERPRIME, S.A. DE C.V. | 500-05-2024-18510 of date September 04, 2024 | Central Administration of Strategic Audit | 10 of September of 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 | CLE080825BP9<br>COMERCIALIZADORA LEZADEL, S.A. DE C.V. | Zapopan, Jalisco | Wholesale trade of distilled beverages from agave | Absence of Assets, Absence of Personnel, Without Material Capacity |
| 2 | CLE190426UG5<br>CREATIVE LEAP, S.A. DE C.V. | Pachuca de Soto, Hidalgo | Legal firms | Absence of Assets, Absence of Personnel, Without Material Capacity |
| 3 | NES190517GA6<br>NESTROCK, S.A. DE C.V. | Pachuca de Soto, Hidalgo | Advertising agencies | Absence of Assets, Absence of Personnel, Without Material Capacity |
| 4 | NEX190523FV3<br>NEXTERITY, S.A. DE C.V. | Toluca, State of Mexico | Retail trade of computers and their accessories | Absence of Assets, Absence of Personnel, Without Material Capacity |
| 5 | QPW160825QQ3<br>QUALITY PRODUCTS WORLWIDE OBM, S.A. DE C.V. | Zapopan, Jalisco | Wholesale trade of telecommunications, photography and cinematography equipment | Absence of Assets, Absence of Personnel, Without Material Capacity |
| 6 | SAAE840201QA0<br>SANCHEZ AREVALO EUGENIO | Tacámbaro, Michoacán | Planting, cultivation and harvesting of avocado | Absence of Assets, Absence of Personnel, Lack of Infrastructure, Without Material Capacity |
| 7 | SCS1804264C1<br>SERVICIOS CORPORATIVOS SERMA, S. DE R.L. DE C.V. | Morelia, Michoacán de Ocampo | Management consulting services | Absence of Assets, Absence of Personnel, Lack of Infrastructure, Without Material Capacity |
| 8 | UPP190508LJ7<br>UPPERPRIME, S.A. DE C.V. | Toluca, State of Mexico | Other services related to real estate services | Absence of Assets, Absence of Personnel, Without Material Capacity |
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