Notice 500-05-2025-10965 Communicating List of Taxpayers Who Challenged Presumption Notices or Resolutions Under Article 69-B of the Federal Tax Code and Obtained Favorable Rulings

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DOF: 23/05/2025

OFFICE 500-05-2025-10965 communicating the list of taxpayers who promoted some means of defense against the presumption notice referred to in the first paragraph of Article 69-B of the Federal Tax Code or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the judicial or administrative body left the aforementioned act without effect.

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 Audit.

OFFICE: 500-05-2025-10965

Subject: Communication of the list of taxpayers who promoted some means of defense against the presumption notice referred to in the first paragraph of Article 69-B of the Federal Tax Code (CFF) or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the judicial or administrative body left the aforementioned act without effect.

This Central Administration of Strategic Audit, attached to the General Administration of Federal Fiscal 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 Gazette of the Federation on December 15, 1995, amended 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, in effect from November 22, 2015, in accordance with what is established in 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 Agency of Customs of Mexico are issued, published in the same official organ on December 21, 2021, in effect 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, in effect from July 23, 2016, in accordance with what is established in the First Transitory Article of said Agreement; in Articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Federal Tax Code, informs you of the following:

That to the taxpayers listed below, a Presumption Notice of non-existence of operations backed by certain fiscal receipts issued by them was notified at the time, 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.

Following the procedure provided for in the aforementioned Article 69-B of the Federal Tax Code, and in terms of the fourth paragraph of the aforementioned article, the taxpayers referred to were notified of the definitive resolution as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Number and date of definitive resolution office

Means of notification to the taxpayer

Authority's public notice board

Personal Notification

Tax Box

Date of posting on the Tax Authority's public notice board

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

01

ALG131204H43

ALVAREZ-PISO LEGAL GROUP, S.C.

500-74-05-04-01-2020- 11097 dated August 13, 2020

September 02, 2020

September 28, 2020

02

HMT170719PD6

HV MN TECNOLOGIA MÉXICO, S.A. DE C.V.

500-05-2021-17560 of June 08, 2021

June 08, 2021

June 09, 2021

03

MCE140410K83

MEJORES CONSTRUCTORES EMPRESARIALES, S.A. DE C.V.

500-69-00-03-03-2023- 9343 dated August 18, 2023

August 24, 2023

August 25, 2023

04

SPM151123I79

SPMEXASES, S.A. DE C.V.

500-72-2019-13404 of October 24, 2019

October 25, 2019

October 28, 2019

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Fiscal Address

Predominant Activity

Reason for the Procedure

01

ALG131204H43

ALVAREZ-PISO LEGAL GROUP, S.C.

ÁLVARO OBREGÓN MAYORALTY, MEXICO CITY

ACCOUNTING AND AUDIT SERVICES

Absence of assets, Absence of personnel

02

HMT170719PD6

HV MN TECNOLOGIA MÉXICO, S.A. DE C.V.

MIGUEL HIDALGO MAYORALTY, MEXICO CITY

ADVERTISING AGENCIES

Absence of assets, Absence of personnel

03

MCE140410K83

MEJOR ES CONSTRUCTORES EMPRESARIALES, S.A. DE C.V.

NAUCALPAN DE JUÁREZ, STATE OF MEXICO

ADMINISTRATION AND SUPERVISION OF CONSTRUCTION OF COMMERCIAL, INSTITUTIONAL AND SERVICE PROPERTIES

Absence of assets, Absence of personnel

04

SPM151123I79

SPMEXASES, S.A. DE C.V.

CUAUHTÉMOC MAYORALTY, MEXICO CITY

INTERMEDIATION TO WHOLESALE TRADE AND OTHER INTERMEDIARIES TO RETAIL TRADE

Absence of assets, Absence of personnel, Lack of infrastructure

For the above reason, the name or corporate name of the taxpayers to whom the aforementioned resolutions were notified, were added to the list referred to in the fourth paragraph of Article 69-B of the Federal Tax Code, which was published in the Official Gazette of the Federation, as indicated below:

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Number and date of office containing in the Global Definitive List

Date of publication in the Official Gazette of the Federation

01

ALG131204H43

ALVAREZ-PISO LEGAL GROUP, S.C.

500-05-2021-5054 dated February 09, 2021

February 22, 2021

02

HMT170719PD6

HV MN TECNOLOGIA MÉXICO, S.A. DE C.V.

500-05-2021-25950 dated August 25, 2021

September 21, 2021

03

MCE140410K83

MEJORES CONSTRUCTORES EMPRESARIALES, S.A. DE C.V.

500-05-2023-26173 dated November 30, 2023

February 01, 2024

04

SPM151123I79

SPMEXASES, S.A. DE C.V.

500-05-2019-40216 dated December 12, 2019

December 27, 2019

Disagreeing with the individual presumption notice or definitive resolution office, they filed means of defense, which were concluded with the following resolutions or sentences:

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Means of defense

Date of the Final Resolution or Sentence

Authority that resolved

Sense and/or effect of the final resolution or sentence

01

ALG131204H43

ALVAREZ-PISO LEGAL GROUP, S.C.

Nullity Trial

9072/21-17-08-3

August 05, 2024

Eighth Regional Metropolitan Chamber of the Federal Tribunal of Administrative Justice

The impugned resolution 500-74-05-04-01- 2020-11097 of August 13, 2020, issued by the Decentralized Administration of Fiscal Audit of Mexico City "4", is declared null and void.

02

HMT170719PD6

HV MN TECNOLOGIA MÉXICO, S.A. DE C.V.

Nullity Trial

25864/22-17-11-4

November 30, 2023

Eleventh Regional Metropolitan Chamber of the Federal Tribunal of Administrative Justice

The fictitious confirmatory resolution issued on the Online Administrative Revocation Recourse RRL2021009293, promoted before the Decentralized Legal Administration of Mexico City "1", as well as the originally appealed 500-05-2021-17560 dated June 08, 2021, issued by the Central Administration of Strategic Audit, are declared null.

03

MCE140410K83

MEJORES CONSTRUCTORES EMPRESARIALES, S.A. DE C.V.

Nullity Trial

2206/23-11-01-2

November 05, 2024

First Regional North-East Chamber of the State of Mexico of the Federal Tribunal of Administrative Justice

The impugned resolution 500-69-00-03-03-2023-9343 of August 18, 2023, issued by the Decentralized Administration of Fiscal Audit of Yucatán "1", is declared null, and orders the authority to carry out the necessary procedures so that the name and Federal Taxpayer Registry of the plaintiff do not appear in the list of taxpayers who did not rebut the presumption provided for in Article 69-B of the Federal Tax Code.

04

SPM151123I79

SPMEXASES, S.A. DE C.V.

Nullity Trial

27875/19-17-08-9

March 08, 2022

Eighth Regional Metropolitan Chamber of the Federal Tribunal of Administrative Justice

The impugned resolution 500-72-2019-13404 of October 24, 2019, issued by the Decentralized Administration of Fiscal Audit of Mexico City "2", is declared null.

In view of the foregoing, it is informed that, as a consequence of the means of defense indicated in the preceding paragraphs, the procedure of Article 69-B of the Federal Tax Code, followed against those taxpayers, has been left without effect.

Finally, it is informed that the fact that the aforementioned taxpayers have obtained a favorable resolution against the presumption notice and/or definitive resolution, does not exempt them from the responsibility they may have regarding other fiscal receipts they have issued without having the assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or produce, commercialize or deliver the goods that backed such receipts, for which reason, the powers of the tax authority are reserved.

Respectfully.

Mexico City, April 08, 2025. - In substitution for the absence of the Central Administrator of Strategic Audit, from the Coordinator of Strategic Audit, from 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 effect, signs:

C.P. Nayeli Margarita Ramos Hernández, Administrator of Strategic Audit "7". - Rubric.

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