Rule · SHCP · 24 Jan 2025 · DOF 5747739
The Strategic Fiscalization Administration notifies taxpayers listed in Annex 1 that they are presumed under Article 69-B, Paragraph One of the Federal Fiscal Code for issuing fiscal receipts without possessing the necessary assets, personnel, infrastructure, or material capacity. These taxpayers have a period of 15 business days from the effective date of the last notification to submit written arguments and supporting documentation to the issuing authority to rebut the presumption. If the facts are not rebutted within this timeframe, the authorities will issue a final resolution, publish the taxpayers' names on the SAT website and in the Official Gazette, and list them as definitively failing to disprove the issuance of fictitious invoicing.
DOF: 24/01/2025
OFFICE 500-05-2024-25842 communicating the global list of taxpayers presumed to fall under the circumstance provided for in Article 69-B, first paragraph of the Federal Fiscal Code.
A logo appears at the margin, saying: Tax Administration Service.- General Administration of Federal Audit.
Central Administration of Strategic Fiscalization.
OFFICE: 500-05-2024-25842
Subject:
Global list of taxpayers presumed to fall under the circumstance provided for in Article 69-B, first paragraph of the Federal Fiscal Code is communicated.
The Central Administration of Strategic Fiscalization, attached to the General Administration of Federal 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 on December 15, 1995, reformed by Decree published in the same Official Journal 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 with Article 22 paragraphs first, 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 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, 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 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 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 Fiscal 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 Fiscal Code, the tax authorities cited in Annex 1 which is an integral part of this office, detected that the taxpayers indicated in said 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.
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 Fiscal Code, therefore in this sense they notified each one 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 Fiscal Code, it is informed to the taxpayers mentioned in said Annex 1 of this office, that they are in the circumstance provided for in the first paragraph of Article 69-B of the Federal Fiscal Code, this is made known to them so that they can manifest before the tax authority that notified them the individual office what is convenient for their rights and provide, before said authorities, the documentation and information 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 Fiscal Code, each of the taxpayers mentioned in said Annex 1 of this office will have a term of 15 business days, counted from when the last of the notifications takes effect, according to the precedence established in Article 69, first paragraph of the Regulations of the Federal Fiscal Code, in correlation with Article 135 of the Federal Fiscal Code, in order to present directly before the offices of the authorities issuing the individual office indicated in Annex 1 of this office, a free writing in original and two copies, signed by the taxpayer or their legal representative in terms of Article 19 of said Code, through which they manifest what is convenient for their rights, attaching to said writing the documentation and information they consider pertinent to disprove the facts detailed in the aforementioned individual office.
The documentation and information presented through the aforementioned writing must comply with the requirements established in Articles 18, 18-A and 19 of the Federal Fiscal Code.
Likewise, they are warned that if the granted term expires without providing the respective proofs, documentation and 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 disproven, proceedings will be taken in terms provided for in the fourth paragraph of Article 69-B of the Federal Fiscal 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 disproven the facts imputed to them and, therefore, are definitely in the situation referred to in the first paragraph of Article 69-B, list which for such effect will be disseminated on the internet page of the Tax Administration Service, and published in the Official Journal of the Federation; the foregoing, since it is in the public interest to stop the invoicing of non-existent operations and that society knows who those taxpayers are who carry out this type of operations.
Respectfully.
Mexico City, November 11, 2024.- In substitution for the absence of the Central Administrator of Strategic Fiscalization, by the Coordinator of Strategic Fiscalization, of the Administrator of Strategic Fiscalization "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, signature: C.P. Nayeli Margarita Ramos Hernández, Administrator of Strategic Fiscalization "7".- Rubric.
Subject:
Annex 1 of office number 500-05-2024-25842 dated November 11, 2024, issued in substitution for the absence of the Central Administrator of Strategic Fiscalization, by CPA Nayeli Margarita Ramos Hernández, Administrator of Strategic Fiscalization "7", of the Central Administration of Strategic Fiscalization, 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 Fiscal Code, it is notified to the taxpayers mentioned in this annex, that they fall under the presumption circumstance provided for in the first paragraph of said Article 69-B of the Federal Fiscal Code.
Below, in the following table, the taxpayers referenced in office number 500-05-2024-25842 dated November 11, 2024 are listed, indicating the date on which the individual presumption office 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 | Means of notification to the taxpayer | ||||||
|---|---|---|---|---|---|---|---|---|---|---|
| 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 | Estrados of the authority | Personal Notification | Notification via Tax Box | ||||
| Date of posting on Estrados of the Fiscal Authority | Date on which notification took effect | Date of notification | Date on which notification took effect | Date of notification | Date on which notification took effect | |||||
| 1 | AESF720120QH2 | ANGEL SANCHEZ FLORA | 500-05-2024-18734 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 2 | AUCL980826SD4 | AZUCENO DE LA CALLEJA LUIS DAVID | 500-05-2024-18735 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 3 | CACI831222927 | CHAGALA COTO ISABEL. | 500-05-2024-18724 dated October 18, 2024 | Central Administration of Strategic Fiscalization | October 24, 2024 | October 25, 2024 | ||||
| 4 | CATJ6211268L0 | CABRERA TRONCOSO J GUADALUPE | 500-18-00-06-02-2024-992 dated October 09, 2024 | Disaggregated Administration of Fiscal Audit of Colima "1" | October 15, 2024 | October 31, 2024 | ||||
| 5 | CJO190515IQ3 | COMERCIALIZADORA JOBE, S.A. DE C.V. | 500-27-00-08-02-2024-08381 dated October 09, 2024 | Disaggregated Administration of Fiscal Audit of Guerrero "1" | October 15, 2024 | October 16, 2024 | ||||
| 6 | CPT101125S54 | COMERCIALIZADORA DE PRODUCTOS DE TRANSFORMACION ECOLOGICA, S.A. DE C.V. | 500-36-05-03-01-2024-14619 dated October 15, 2024 | Disaggregated Administration of Fiscal Audit of Mexico "2" | October 21, 2024 | October 22, 2024 | ||||
| 7 | DIS2109083Q9 | DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V. | 500-54-00-02-01-2024-3556 dated November 01, 2024 | Disaggregated Administration of Fiscal Audit of Sonora "1" | November 04, 2024 | November 05, 2024 | ||||
| 8 | FOBM891231TQ4 | FLORES BRETON MARISOL | 500-46-00-05-02-2024-19272 dated November 01, 2024 | Disaggregated Administration of Fiscal Audit of Puebla "2" | November 07, 2024 | November 08, 2024 | ||||
| 9 | GAMX6902059U9 | GARCIA MORENO XOCHITL GUADALUPE | 500-46-00-05-02-2024-19269 dated November 01, 2024 | Disaggregated Administration of Fiscal Audit of Puebla "2" | November 07, 2024 | November 08, 2024 | ||||
| 10 | GEMO831214E50 | GERARDO MUÑOZ OSCAR | 500-46-00-05-02-2024-19270 dated November 01, 2024 | Disaggregated Administration of Fiscal Audit of Puebla "2" | November 07, 2024 | November 08, 2024 | ||||
| 11 | GOBF770501M70 | GONZALEZ BOBADILLA JOSE FELIPE | 500-05-2024-18725 dated October 18, 2024 | Central Administration of Strategic Fiscalization | October 24, 2024 | October 25, 2024 | ||||
| 12 | GOGA771110RN5 | GONZAGA RODRIGUEZ GONZALEZ ANA ELENA | 500-05-2024-18729 dated October 24, 2024 | Central Administration of Strategic Fiscalization | October 30, 2024 | October 31, 2024 | ||||
| 13 | GORA950507ER6 | GONZALEZ RIVERA ALVARO IVAN | 500-05-2024-18756 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 14 | GUFI851011747 | GUERRERO FENTANES IVAN KARLO | 500-05-2024-18779 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 15 | JAMB950908KJA | JACOBO MENDEZ BRENDA | 500-05-2024-18731 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 16 | JITJ651225SG9 | JIMENEZ TORRES MA. JESUS | 500-05-2024-18732 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 17 | LPR200508961 | LRP PRODUCE, S.A. DE C.V. | 500-46-00-05-02-2024-19268 dated November 01, 2024 | Disaggregated Administration of Fiscal Audit of Puebla "2" | November 05, 2024 | November 06, 2024 | ||||
| 18 | NARD800806132 | NAVARRO ROMERO DANIEL | 500-58-00-05-01-2024-1986 dated October 24, 2024 | Disaggregated Administration of Fiscal Audit of Tamaulipas "1" | October 30, 2024 | October 31, 2024 | ||||
| 19 | PEGF800627B28 | PEREZ GONZALEZ FABIOLA | 500-05-2024-18730 dated October 24, 2024 | Central Administration of Strategic Fiscalization | October 30, 2024 | October 31, 2024 | ||||
| 20 | PEPE630927BA0 | PEREZ PEREZ MARIA ESTELA | 500-05-2024-18726 dated October 18, 2024 | Central Administration of Strategic Fiscalization | October 24, 2024 | October 25, 2024 | ||||
| 21 | PRM0408127D2 | PRINCIPAL RENTALS DE MEXICO, S.A. DE C.V. | 500-72-06-01-01-2024-29356 dated October 23, 2024 | Disaggregated Administration of Fiscal Audit of Distrito Federal "2" | October 29, 2024 | October 30, 2024 | ||||
| 22 | QUSE871116KA9 | QUINTERO SEGOVIA ERICK EDMUNDO | 500-05-2024-18733 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 23 | ROMA940205JJ8 | RODRIGUEZ MENDIETA ARELY ANDREA | 500-05-2024-18723 dated October 18, 2024 | Central Administration of Strategic Fiscalization | October 24, 2024 | October 25, 2024 | ||||
| 24 | SCB160224CAA | SUMINISTROS Y CONSTRUCCIONES BIMARVI, S.A. DE C.V. | 500-05-2024-18780 dated October 30, 2024 | Central Administration of Strategic Fiscalization | November 05, 2024 | November 06, 2024 | ||||
| 25 | TAR150828L32 | TRAMITADORA ADUANAL DE REYNOSA, S.A. DE C.V. | 500-61-00-04-00-2024-12633 dated September 27, 2024 | Disaggregated Administration of Fiscal Audit of Tamaulipas "4" | October 02, 2024 | October 03, 2024 | ||||
| 26 | VEFM750608VA9 | VELASQUEZ FERNANDEZ MARCO ANTONIO | 500-04-03-00-00-2024-21387 dated October 14, 2024 | Central Administration of Verification and Evaluation of Federative Entities in Matters of Fiscal Coordination | October 17, 2024 | October 18, 2024 |
Additional data of the taxpayers.
| R.F.C. | Name, denomination or trade name of the Taxpayer | Fiscal Address | Preponderant Activity | Reason for Procedure | |
|---|---|---|---|---|---|
| 1 | AESF720120QH2 | ANGEL SANCHEZ FLORA | Mazatlán, Sinaloa. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 2 | AUCL980826SD4 | AZUCENO DE LA CALLEJA LUIS DAVID | Tlalpan, Mexico City | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 3 | CACI831222927 | CHAGALA COTO ISABEL. | Mazatlán, Sinaloa. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 4 | CATJ6211268L0 | CABRERA TRONCOSO J GUADALUPE | León, Guanajuato | Wholesale trade of other construction materials, except wood, Wholesale trade of chemicals for industrial use, Wholesale trade of containers, paper and cardboard among others | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 5 | CJO190515IQ3 | COMERCIALIZADORA JOBE, S.A. DE C.V. | Acapulco de Juárez, Guerrero | Wholesale trade of other construction materials, except wood and wholesale trade of cement, brick and gravel. | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 6 | CPT101125S54 | COMERCIALIZADORA DE PRODUCTOS DE TRANSFORMACION ECOLOGICA, S.A. DE C.V. | Tlalnepantla de Baz, State of Mexico. | Sale in national territory of other fuels | Absence of assets, Absence of personnel, No material capacity. |
| 7 | DIS2109083Q9 | DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V. | Hermosillo, Sonora | Construction of commercial, institutional and service buildings | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 8 | FOBM891231TQ4 | FLORES BRETON MARISOL | Puebla, Puebla | Manufacturing of energy distribution equipment and appliances | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 9 | GAMX6902059U9 | GARCIA MORENO XOCHITL GUADALUPE | Cuautlancingo, Puebla | Salaried worker | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 10 | GEMO831214E50 | GERARDO MUÑOZ OSCAR | Puebla, Puebla | Salaried worker | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 11 | GOBF770501M70 | GONZALEZ BOBADILLA JOSE FELIPE | Mazatlán, Sinaloa. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 12 | GOGA771110RN5 | GONZAGA RODRIGUEZ GONZALEZ ANA ELENA | Gustavo A. Madero, Mexico City. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 13 | GORA950507ER6 | GONZALEZ RIVERA ALVARO IVAN | Frontera, Coahuila de Zaragoza. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 14 | GUFI851011747 | GUERRERO FENTANES IVAN KARLO | Tlalpan, Mexico City. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 15 | JAMB950908KJA | JACOBO MENDEZ BRENDA | Nicolás Romero, State of Mexico. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 16 | JITJ651225SG9 | JIMENEZ TORRES MA. JESUS | Tlalpan, Mexico City | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 17 | LPR200508961 | LRP PRODUCE, S.A. DE C.V. | Puebla, Puebla | Sand and gravel mining for construction | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 18 | NARD800806132 | NAVARRO ROMERO DANIEL | Victoria, Tamaulipas | Construction of urbanization works | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 19 | PEGF800627B28 | PEREZ GONZALEZ FABIOLA | Mazatlán, Sinaloa. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 20 | PEPE630927BA0 | PEREZ PEREZ MARIA ESTELA | Mazatlán, Sinaloa. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 21 | PRM0408127D2 | PRINCIPAL RENTALS DE MEXICO, S.A. DE C.V. | Cuauhtémoc, Mexico City | Cellular telephony | Absence of assets, Absence of personnel, No material capacity. |
| 22 | QUSE871116KA9 | QUINTERO SEGOVIA ERICK EDMUNDO | Culiacán, Sinaloa | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 23 | ROMA940205JJ8 | RODRIGUEZ MENDIETA ARELY ANDREA | Nezahualcóyotl, State of Mexico. | Repair and maintenance of industrial machinery and equipment | Absence of assets, Absence of personnel, No material capacity. |
| 24 | SCB160224CAA | SUMINISTROS Y CONSTRUCCIONES BIMARVI, S.A. DE C.V. | Benito Juárez, Mexico City. | Wholesale trade of machinery and equipment for construction and mining | Absence of assets, Absence of personnel, No material capacity. |
| 25 | TAR150828L32 | TRAMITADORA ADUANAL DE REYNOSA, S.A. DE C.V. | Reynosa, Tamaulipas | Commercialization of Hydrocarbons | Absence of assets, Absence of personnel, Lack of Infrastructure, No material capacity. |
| 26 | VEFM750608VA9 | VELASQUEZ FERNANDEZ MARCO ANTONIO | Celaya Guanajuato | Manufacture of metal structures | Absence of assets, Absence of personnel, No material capacity. |
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“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 paragraphs first, fraction VIII, and last, numeral 5, of the Internal R…”
“Article Third, fraction I, subsection a), of the Agreement by which various attributions are delegated to the Public Servants of the Tax Administration Service”
“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”
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