Regulatory Alerts2025-04-25 | DOF 5755868Added
Notice 500-05-2025-10773 communicating the definitive global list under Article 69-B, fourth paragraph of the Federal Tax Code
The Strategic Taxation Administration of the SAT publishes the definitive global list of six taxpayers who failed to rebut the presumption that they issued fiscal receipts without assets, personnel, infrastructure, or material capacity. The taxpayers, identified by their tax ID numbers and names in Annex 1, are permanently classified under Article 69-B of the Federal Tax Code, meaning their issued fiscal receipts produce no fiscal effect. This publication follows the expiration of the 15-day period granted for rebuttal and the subsequent issuance of definitive resolutions rejecting the taxpayers' arguments.
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DOF: 25/04/2025
OFFICE 500-05-2025-10773 communicating the definitive global list under Article 69-B, fourth paragraph of the Federal Tax Code
At the margin, a seal with the National Coat of Arms, which reads: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Taxation.
OFFICE: 500-05-2025-10773
Subject:
Communicating the definitive global list 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 the provisions of Article 16, first paragraph, of the Political Constitution of the United Mexican States; Articles 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, amended by Decree published in the same Official Gazette on June 12, 2003; Articles 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 the provisions of the first paragraph of the First Transitory Article of said Regulations and amended by Decree amending and adding various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Tax Administration Service, 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, effective from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, fraction I, subsection a), of the Agreement by which various powers are delegated to 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 the provisions of the First Transitory Article of said Agreement; as well as 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 notice, 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.
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 said Annex 1, and in said notice, the reasons and grounds were indicated for which the taxpayers fell into 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 notice, which is an integral part thereof.
On the other hand, the global presumption list was notified on the internet page of the Tax Administration Service; and by publication in the Official Gazette of the Federation (DOF) in the terms specified in Annex 1, sections B and C, of this notice, which is an integral part thereof, the foregoing 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 to the provisions of the second paragraph of Article 69-B of the Federal Tax Code, in the individual presumption notices, the tax authorities granted each taxpayer a period 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 made known through the aforementioned notices, warned that if, after the granted period had elapsed, they did not provide the documentation and information and/or what they exhibited, once evaluated, did not rebut the facts indicated in the notices in question, the authorities would proceed in terms of the fourth paragraph of Article 69-B of the Federal Tax Code, first to notify them of 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 made known and therefore, would be in a definitive situation referred to in the first paragraph of said Article 69-B of the Federal Tax Code.
Once the period indicated in the previous paragraph has elapsed, and in view of the fact that those taxpayers during the period established in the second paragraph of Article 69-B of the Federal Tax Code, in exercise of the right provided for in said legal provision, presented, through the means indicated in the individual resolutions themselves, various information, documentation, and arguments in order to rebut the facts made known in the aforementioned individual notices, and said authorities proceeded to the admission and evaluation of the same.
As a result of the evaluation mentioned in the preceding paragraph, and in view of the fact that with the arguments manifested and evidence 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 paragraphs preceding each of the taxpayers indicated in Annex 1, section D, of this notice.
For the aforementioned reasons, 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, to date, said period has elapsed since the notification of the resolution and, in addition, the aforementioned authorities have not been notified of any resolution or judgment 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, which has been initiated against them; therefore, in order to fully comply with Resolutive Third contained in the aforementioned 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 this, proceeds to add the names, denominations, or trade names of the taxpayers indicated in Annex 1 of this notice, to 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 said Article 69-B of the Federal Tax Code, for the reasons and grounds indicated in the definitive resolutions notified to each of them, a 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 consider, with general effects, that the fiscal receipts issued by said taxpayers do not and did not produce any fiscal effect, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the foregoing, since it is in the public interest to stop the invoicing of non-existent operations, as well as for society to know who those taxpayers are who carry out this type of operations.
Respectfully.
Mexico City, March 19, 2025. - In substitution for the absence of the Central Administrator of Strategic Taxation, by the Coordinator of Strategic Taxation, of the Administrator of Strategic Taxation "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.
Annex 1 of notice number 500-05-2025-10773 dated March 19, 2025, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT rebut the reason for which they were notified of the presumption notice, 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
Means of notification to the taxpayer
At the authority's desk
Personal notification
Notification via Tax Box
Date of posting
at the authority's desk
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
CCO1501143N6
CONSULTORIA CONIA, S.A.
DE C.V.
500-05-2024-18335 of
date July 31,
2024
Central Administration
of Strategic Taxation
August 06, 2024
August 07,
2024
2
CTA190519J87
CONSTRUCTORA TAHDHIB,
S.A. DE C.V.
500-05-2024-18315 of
date July 31,
2024
Central Administration
of Strategic Taxation
August 06, 2024
August 07,
2024
3
CVE1710054D7
COMERCIALIZADORA VEMX,
S.A. DE C.V.
500-42-00-05-01-2024-
03188 of date June 19,
2024
Administration
Decentralized Fiscal Audit of
Nuevo León "2"
June 25, 2024
June 26, 2024
4
IFU020930HQ2
INMOBILIARIA LAS
FUENTES, S.A. DE C.V.
500-46-00-05-02-2024-
17759 of date October 11,
2024
Administration
Decentralized Fiscal Audit of
Puebla "2"
October 17, 2024
October 18, 2024
5
MAN1708282Q9
MANFIT, S.A. DE C.V.
500-27-00-08-02-2021-
03528 of date April 19,
2021
Administration
Decentralized Fiscal Audit of
Guerrero "1"
April 26, 2021
April 27, 2021
6
MED1603291D9
MEDUTEC, S.A. DE C.V.
500-42-00-05-03-2024-
03258 of date June 25,
2024
Administration
Decentralized Fiscal Audit of
Nuevo León "2"
July 01, 2024
July 02, 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
notification took effect
1
CCO1501143N6
CONSULTORIA CONIA, S.A. DE C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
August 09, 2024
August 12, 2024
2
CTA190519J87
CONSTRUCTORA TAHDHIB, S.A. DE
C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
August 09, 2024
August 12, 2024
3
CVE1710054D7
COMERCIALIZADORA VEMX, S.A. DE
C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
August 09, 2024
August 12, 2024
4
IFU020930HQ2
INMOBILIARIA LAS FUENTES, S.A. DE
C.V.
500-05-2024-18755 of date October 21,
2024
Central Administration of
Strategic Taxation
October 21, 2024
October 22, 2024
5
MAN1708282Q9
MANFIT, S.A. DE C.V.
500-05-2021-15199 of date June 01,
2021
Central Administration of
Strategic Taxation
June 01, 2021
June 02, 2021
6
MED1603291D9
MEDUTEC, S.A. DE C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
August 09, 2024
August 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
notification took effect
1
CCO1501143N6
CONSULTORIA CONIA, S.A. DE C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
October 18, 2024
October 21, 2024
2
CTA190519J87
CONSTRUCTORA TAHDHIB, S.A. DE
C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
October 18, 2024
October 21, 2024
3
CVE1710054D7
COMERCIALIZADORA VEMX, S.A. DE
C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
October 18, 2024
October 21, 2024
4
IFU020930HQ2
INMOBILIARIA LAS FUENTES, S.A. DE
C.V.
500-05-2024-18755 of date October 21,
2024
Central Administration of
Strategic Taxation
November 08, 2024
November 11, 2024
5
MAN1708282Q9
MANFIT, S.A. DE C.V.
500-05-2021-15199 of date June 01,
2021
Central Administration of
Strategic Taxation
June 14, 2021
June 15, 2021
6
MED1603291D9
MEDUTEC, S.A. DE C.V.
500-05-2024-18379 of date August 09,
2024
Central Administration of
Strategic Taxation
October 18, 2024
October 21, 2024
Section D.- Notification of the DEFINITIVE 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
Means of notification to the taxpayer
At the authority's desk
Personal notification
Notification via Tax
Box
Date of posting
at the authority's desk
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
CCO1501143N6
CONSULTORIA CONIA, S.A. DE
C.V.
500-05-2025-5668 of
date January 23,
2025
Central Administration
of Strategic Taxation
January 29, 2025
January 30, 2025
2
CTA190519J87
CONSTRUCTORA TAHDHIB,
S.A. DE C.V.
500-05-2025-5709 of
date January 23,
2025
Central Administration
of Strategic Taxation
January 29, 2025
January 30, 2025
3
CVE1710054D7
COMERCIALIZADORA VEMX,
S.A. DE C.V.
500-42-00-05-01-2025-
01270 of date January 13,
2025
Administration
Decentralized Fiscal Audit of
Nuevo León "2"
January 14, 2025
January 15, 2025
4
IFU020930HQ2
INMOBILIARIA LAS FUENTES,
S.A. DE C.V.
500-46-00-05-02-2025-
4532 of date January 22,
2025
Administration
Decentralized Fiscal Audit of
Puebla "2"
January 23, 2025
January 24, 2025
5
MAN1708282Q9
MANFIT, S.A. DE C.V. // In
compliance with the judgment of
date June 23, 2022,
issued by the Regional Chamber of
the Pacific and Auxiliary of the Federal
Administrative Justice Tribunal, within the Nullity Trial 791/21-14-01-3.
500-27-00-08-02-2024-
08507 of date November 28,
2024
Administration
Decentralized Fiscal Audit of
Guerrero "1"
December 04,
2024
December 05,
2024
6
MED1603291D9
MEDUTEC, S.A. DE C.V.
500-42-00-05-03-2025-
01288 of date January 14,
2025
Administration
Decentralized Fiscal Audit of
Nuevo León "2"
January 20, 2025
January 21, 2025
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
CCO1501143N6
CONSULTORIA CONIA, S.A. DE C.V.
Guadalajara, Jalisco
Other wholesale trade intermediaries
Absence of Assets, Absence of Personnel, Without
Material Capacity
2
CTA190519J87
CONSTRUCTORA TAHDHIB, S.A. DE C.V.
Querétaro, Querétaro
Construction of commercial, institutional
and service buildings
Absence of Assets, Absence of Personnel, Without
Material Capacity
3
CVE1710054D7
COMERCIALIZADORA VEMX, 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, Without Material Capacity
4
IFU020930HQ2
INMOBILIARIA LAS FUENTES, S.A. DE C.V.
Puebla, Puebla
Rental of other real estate
Absence of Assets, Absence of Personnel, Lack
of Infrastructure, Without Material Capacity
5
MAN1708282Q9
MANFIT, S.A. DE C.V.
Taxco de Alarcón, Guerrero
Other civil engineering or heavy construction works,
accounting and auditing services, other specialized
work for construction and other
wholesale trade intermediaries
Absence of Assets, Absence of Personnel, Lack
of Infrastructure, Without Material Capacity
6
MED1603291D9
MEDUTEC, S.A. DE C.V.
San Nicolás de los Garza, Nuevo
León
Alienation of trademark rights
Absence of Assets, Lack of Infrastructure, Without
Material Capacity
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