2025-04-25 | DOF 5755869Added
The Strategic Fiscalization Central Administration of the SAT publishes the definitive global list of taxpayers who failed to rebut the presumption that they issued fiscal receipts without assets, personnel, infrastructure, or material capacity. This action finalizes the status of the listed entities under Article 69-B of the Federal Tax Code in force until July 24, 2018, declaring that fiscal receipts issued by them produce no fiscal effect. The list includes Procedimientos Administrativos Universales, S.A. de C.V., which was notified of the definitive resolution on June 10, 2024.
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DOF: 25/04/2025
OFFICE 500-05-2025-10774 communicating the definitive global list under Article 69-B, paragraph three of the Federal Tax Code in force until July 24, 2018
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
Strategic Fiscalization Central Administration.
OFFICE: 500-05-2025-10774
Subject:
The definitive global list is communicated under Article
69-B, paragraph three of the Federal Tax Code
in force until July 24, 2018.
The Strategic Fiscalization Central Administration, attached to the General Administration of Federal Fiscal Audit of the Tax Administration Service, based on the provisions of 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
Federación on December 15, 1995, reformed by Decree published in the same Official Gazette of the
Federación 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, number 5, of the Internal Regulations of the Tax Administration Service published
in the Official Gazette of the Federación on August 24, 2015, in force from November 22, 2015, in
conformity with the provisions of 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 Treasury 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 conformity with the provisions of the First Transitory Article of said Decree; Third Article,
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 Federación on June 23,
2016, in force from July 23, 2016, in conformity with the provisions of the First Transitory Article
of said Agreement; as well as in Articles 33, last paragraph, 63, of the Federal Tax Code
in force and 69-B, paragraphs first, third and fourth of the Federal Tax Code in force until July 24,
2018, in relation to the Second Transitory Article of the "DECREE by which Article
69-B of the Federal Tax Code is reformed", published in the Official Gazette of the Federación on June 25,
2018 and Transitory Article Twenty-Fourth, fraction I) of the Fiscal Miscellany Resolution for 2025,
published in the Official Gazette of the Federación on December 30, 2024, notifies the following:
As a result of the exercise of the powers and faculties indicated in Article 69-B, paragraphs first and
second of the Federal Tax Code in force until July 24, 2018, 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 fiscal receipts without having the assets, personnel,
infrastructure or material capacity to provide the services or produce, commercialize or deliver the goods
that cover such receipts.
Having detected such a situation, the tax authority in order to comply with Article 69-B, paragraph second, of the
Federal Tax Code in force until July 24, 2018, as well as with number 69 of the Regulations
of said Code, issued an individual presumption office 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 of the
Federación in force until July 24, 2018.
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 part
integral of it.
On the other hand, the global presumption list was notified on the website of the
Tax Administration Service; and through publication in the Official Gazette of the Federación (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 conformity with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax
Code in force, in correlation with 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 force until July 24, 2018, in the individual presumption offices the tax authorities granted
to each taxpayer a period of fifteen business days counted from the last of the notifications before
effective, to make the statements and provide the evidence they considered pertinent
to rebut the facts made known through the aforementioned offices, warned that if the
granted period elapsed without providing the documentation and information and/or the that exhibited, once valued, did not
rebut the facts indicated in the offices of merit, it would proceed by said authorities in
terms of the third paragraph of Article 69-B of the Federal Tax Code in force until July 24,
2018, 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 given
to know and therefore, would be in definitive form in the situation referred to in the first paragraph of the
cited Article 69-B of the Federal Tax Code in force until July 24, 2018.
Once the period indicated in the preceding paragraph has elapsed, and in virtue that those taxpayers during the
period established in the second paragraph of Article 69-B of the Federal Tax Code in force until
July 24, 2018, in exercise of the right provided for in the cited 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 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
expressed and evidence provided by those taxpayers the aforementioned authorities considered that
those taxpayers did not rebut the facts imputed to them in the individual offices of presumption
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 third paragraph of Article 69-B of the Federal
Tax Code in force until July 24, 2018, in relation to the Second Transitory Article
of the "DECREE by which Article 69-B of the Federal Tax Code is reformed", published in the
Official Gazette of the Federación on June 25, 2018, states that in no case will the list be published
before the thirty business days following the notification of the resolution and that, at the date has elapsed said
period 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,
in force until July 24, 2018, that has been initiated against them; therefore, with the purpose of giving full
compliance to Resolutive Third contained in the aforementioned definitive resolutions, this Administration
Central of Strategic Fiscalization, 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 rebut the facts
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 in force until July 24, 2018, by the
reasons and grounds indicated in the definitive resolutions notified to each of them, list that
will be published on the website of the Tax Administration Service (www.sat.gob.mx)
as well as in
the Official Gazette of the Federación, in order to consider, with general effects, that the fiscal receipts
issued by said taxpayers do not produce nor did they produce any fiscal effect, such as it is
declared by the fourth paragraph of Article 69-B of the Federal Tax Code in force until July 24,
2018; the above, since it is of public interest that the billing of operations
be stopped nonexistent, as well as that society knows 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 Fiscalization, of the Coordinator of Strategic Fiscalization, of the Administrator of Fiscalization
Strategic "1", "2", "3", "4", "5" and "6", based on Articles 4, fourth paragraph, and 22, last paragraph,
number 5 subsection h), of the Internal Regulations of the Tax Administration Service in force, signs: C.P.
Nayeli Margarita Ramos Hernández, Administrator of Strategic Fiscalization "7". - Rubric.
Annex 1 of office number 500-05-2025-10774 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 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 PRESUMPTION OFFICE in accordance with paragraphs first and second
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 office of
presumption
Issuing authority of the
individual office of
presumption
Means of notification to the taxpayer
Authority's bench
Personal notification
Notification via Tax Box
Date of posting on
the benches of the
Fiscal Authority
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
PAU121218K18
PROCEDIMIENTOS
ADMINISTRATIVOS
UNIVERSALES, S.A. DE
C.V.
500-49-00-06-01-
2017-004432 of
date June 01,
2017
Administration
Decentralized of
Fiscal Audit of
Quintana Roo "2"
June 02,
2017
June 05,
2017
Section B.- Notification on the website 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 global office
of presumption
Date of notification on the website of the
Tax Administration Service
Date on which the notification
took effect
1
PAU121218K18
PROCEDIMIENTOS ADMINISTRATIVOS
UNIVERSALES, S.A. DE C.V.
500-05-2017-16234 of date June 30
of 2017
Central Administration of
Strategic Fiscalization
July 03, 2017
July 04, 2017
Section C.- Notification in the Official Gazette of the Federación.
R.F.C.
Name, denomination or trade name of the
Taxpayer
Number and date of global office of
presumption
Issuing authority of the global office
of presumption
Date of notification in the Official
Gazette of the Federación
Date on which the notification
took effect
1
PAU121218K18
PROCEDIMIENTOS ADMINISTRATIVOS
UNIVERSALES, S.A. DE C.V.
500-05-2017-16234 of date June 30
of 2017
Central Administration of
Strategic Fiscalization
July 13, 2017
July 14, 2017
Section D.- Notification of the definitive RESOLUTION office in accordance with the third paragraph of
Article 69-B of the Federal Tax Code in force until July 24, 2018.
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
Authority's bench
Personal notification
Notification via Tax Box
Date of posting on
the benches of the
Fiscal Authority
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
PAU121218K18
PROCEDIMIENTOS
ADMINISTRATIVOS UNIVERSALES,
S.A. DE C.V. // In compliance with the
sentence of date March 03, 2023,
issued by the First Regional Metropolitan
Sala of the Federal Tribunal of
Administrative Justice, within the Trial
of Nullity 25928/21-17-01-3
500-49-00-06-01-
2024-0007039 of
date June 03
of 2024
Administration
Decentralized of
Fiscal Audit of
Quintana Roo "2"
June 07,
2024
June 10,
2024
Section E.- Additional data of taxpayers.
R.F.C.
Name, denomination or trade name of the Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
1
PAU121218K18
PROCEDIMIENTOS ADMINISTRATIVOS UNIVERSALES, S.A.
DE C.V.
Cuauhtémoc, Mexico City
Business Administration Services
Absence of Assets, Absence of Personnel, Lack of
Infrastructure
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