Regulatory Alerts2025-05-30 | DOF 5758802Added · Updated
Notice 500-05-2025-12249 Communicating the Definitive Global List Under Article 69-B, Paragraph Four of the Federal Tax Code
The Strategic Fiscal Audit Central Administration publishes the definitive global list of nine taxpayers whose names, denominations, or corporate names are added to the registry of contributors who failed to disprove facts regarding the issuance of fiscal receipts without assets, personnel, infrastructure, or material capacity. This action finalizes the presumption that the fiscal receipts issued by these entities produce no fiscal effect, following the expiration of the 15-business-day period for rebuttal and the mandatory 30-business-day waiting period after the notification of definitive resolutions. The publication serves to inform the public and deter the billing of non-existent operations by identifying those definitively located under the first paragraph of Article 69-B of the Federal Tax Code.
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DOF: 05/30/2025
OFFICE 500-05-2025-12249 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 Audit.
OFFICE: 500-05-2025-12249.
SUBJECT: COMMUNICATION OF THE DEFINITIVE GLOBAL LIST UNDER ARTICLE 69-B, FOURTH PARAGRAPH 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 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 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; 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 what is established in the first paragraph of the First Transitory Article of said Regulations and reformed by Decree reforming 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, 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 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 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 the aforementioned Annex 1, and in said notice, the reasons and grounds were indicated for which the taxpayers were located in the hypothesis mentioned 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 thereof.
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 thereof, 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 to 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 disprove the facts made known through the aforementioned notices, warned that if the granted term elapsed without providing the documentation and information and/or what was exhibited, once evaluated, did not disprove the facts indicated in the notices in question, 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 of the definitive individual resolution, as well as to publish their names, denominations, or corporate names in the list of taxpayers who did not disprove the facts made known and therefore, would be definitively in the 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 view of the fact that those taxpayers during the term established in the second paragraph of Article 69-B of the Federal Tax Code, did not appear before the corresponding tax authority, despite being duly notified, and therefore did not present any documentation aimed at disproving the facts made known through the aforementioned individual notices, the warning became effective, and the tax authorities proceeded to issue the definitive individual resolutions in which it was determined that by not appearing before the authority, they did not disprove the facts imputed to them, and therefore, the hypothesis provided for in the first paragraph of this Article 69-B of the Federal Tax Code is definitively updated, for the reasons exposed in said definitive resolutions.
It should be noted that the definitive resolutions indicated in the previous paragraph were duly notified in the terms indicated in the paragraphs preceding each of the taxpayers indicated in Annex 1, section D of this office.
For the above stated 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 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, which has been initiated against them; therefore, with the purpose of fully complying with 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 corporate names of the taxpayers indicated in Annex 1 of this office, in the list of taxpayers who did not disprove the facts imputed to them and therefore, are definitively in the 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, in order to consider, with general effects, that the fiscal receipts issued by said taxpayers did not produce nor did they produce any fiscal effect, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the above, since it is in the public interest to stop the billing 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, April 15, 2025. - In substitution for the absence of the Central Administrator of Strategic Audit, by the Coordinator of Strategic Audit, by 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 500-05-2025-12249 dated April 15, 2025, corresponding to taxpayers who DID NOT provide arguments or evidence to disprove the reason for which they were notified of the presumption office, 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 OFFICE 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 corporate name of the Taxpayer | Number and date of individual presumption office | Issuing Authority of the individual presumption office | Notification Medium to the Taxpayer |
|---|---|---|---|---|
| Authority's Bench | ||||
| Date of posting on the Authority's Bench | ||||
| 1 | LSC140728T18 | LOLMEX SOLUCIONES COMERCIALES, S.A. DE C.V. | 500-05-2024-18672 dated October 4, 2024 | Central Administration of Strategic Audit |
| 2 | MCO131121869 | MACO CONCRETOS, S.A. DE C.V. | 500-05-2024-18503 dated September 18, 2024 | Central Administration of Strategic Audit |
| 3 | MEB130710280 | MULTICOMERCIAL Y EMPRESARIAL BUSHRA, S.A. DE C.V. | 500-05-2024-18449 dated September 2, 2024 | Central Administration of Strategic Audit |
| 4 | MZO170829397 | MULTISERVICIOS ZORDIN, S.A. DE C.V. | 500-05-2024-18451 dated September 2, 2024 | Central Administration of Strategic Audit |
| 5 | PAL201002KG5 | PALADIN ALIMENTOS, S.A. DE C.V. | 500-05-2024-18453 dated September 23, 2024 | Central Administration of Strategic Audit |
| 6 | PEGE870503D46 | PEREZ GAYTAN EDITH ADRIANA | 500-05-2024-18499 dated September 2, 2024 | Central Administration of Strategic Audit |
| 7 | PSS160421J24 | PRESTADORA DE SERVICIOS SKYNER, S.A. DE C.V. | 500-05-2024-18452 dated September 2, 2024 | Central Administration of Strategic Audit |
| 8 | SELB950111L47 | SERRANO LOPEZ BEATRIZ GUADALUPE | 500-05-2024-18500 dated September 2, 2024 | Central Administration of Strategic Audit |
| 9 | UUCS660303851 | URZUA CARTAGENA SOLEDAD | 500-05-2024-18501 dated September 2, 2024 | Central Administration of Strategic Audit |
Section B.- Notification on the Internet page of the Tax Administration Service
| R.F.C. | Name, denomination or corporate name of the Taxpayer | Number and date of global presumption office | Issuing Authority of the global presumption office | Date of notification on the Internet page of the Tax Administration Service | Date on which notification took effect |
|---|---|---|---|---|---|
| 1 | LSC140728T18 | LOLMEX SOLUCIONES COMERCIALES, S.A. DE C.V. | 500-05-2024-18755 dated October 21, 2024 | Central Administration of Strategic Audit | October 21, 2024 |
| 2 | MCO131121869 | MACO CONCRETOS, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 3 | MEB130710280 | MULTICOMERCIAL Y EMPRESARIAL BUSHRA, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 4 | MZO170829397 | MULTISERVICIOS ZORDIN, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 5 | PAL201002KG5 | PALADIN ALIMENTOS, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 6 | PEGE870503D46 | PEREZ GAYTAN EDITH ADRIANA | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 7 | PSS160421J24 | PRESTADORA DE SERVICIOS SKYNER, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 8 | SELB950111L47 | SERRANO LOPEZ BEATRIZ GUADALUPE | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
| 9 | UUCS660303851 | URZUA CARTAGENA SOLEDAD | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | October 8, 2024 |
Section C.- Notification in the Official Gazette of the Federation.
| R.F.C. | Name, denomination or corporate name of the Taxpayer | Number and date of global presumption office | Issuing Authority of the global presumption office | Date of notification in the Official Gazette of the Federation | Date on which notification took effect |
|---|---|---|---|---|---|
| 1 | LSC140728T18 | LOLMEX SOLUCIONES COMERCIALES, S.A. DE C.V. | 500-05-2024-18755 dated October 21, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 2 | MCO131121869 | MACO CONCRETOS, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 3 | MEB130710280 | MULTICOMERCIAL Y EMPRESARIAL BUSHRA, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 4 | MZO170829397 | MULTISERVICIOS ZORDIN, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 5 | PAL201002KG5 | PALADIN ALIMENTOS, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 6 | PEGE870503D46 | PEREZ GAYTAN EDITH ADRIANA | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 7 | PSS160421J24 | PRESTADORA DE SERVICIOS SKYNER, S.A. DE C.V. | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 8 | SELB950111L47 | SERRANO LOPEZ BEATRIZ GUADALUPE | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
| 9 | UUCS660303851 | URZUA CARTAGENA SOLEDAD | 500-05-2024-18678 dated October 8, 2024 | Central Administration of Strategic Audit | November 8, 2024 |
Section D.- Notification of the OFFICE OF DEFINITIVE RESOLUTION in accordance with the fourth paragraph of Article 69-B of the Federal Tax Code.
| R.F.C. | Name, denomination or corporate name of the Taxpayer | Number and date of definitive resolution | Issuing Authority of the definitive resolution | Notification Medium to the Taxpayer |
|---|---|---|---|---|
| Authority's Bench | ||||
| Date of posting | ||||
| 1 | LSC140728T18 | LOLMEX SOLUCIONES COMERCIALES, S.A. DE C.V. | 500-05-2025-5843 dated February 10, 2025 | Central Administration of Strategic Audit |
| 2 | MCO131121869 | MACO CONCRETOS, S.A. DE C.V. | 500-05-2025-5830 dated February 6, 2025 | Central Administration of Strategic Audit |
| 3 | MEB130710280 | MULTICOMERCIAL Y EMPRESARIAL BUSHRA, S.A. DE C.V. | 500-05-2025-5831 dated February 6, 2025 | Central Administration of Strategic Audit |
| 4 | MZO170829397 | MULTISERVICIOS ZORDIN, S.A. DE C.V. | 500-05-2025-5837 dated February 7, 2025 | Central Administration of Strategic Audit |
| 5 | PAL201002KG5 | PALADIN ALIMENTOS, S.A. DE C.V. | 500-05-2025-5838 dated February 7, 2025 | Central Administration of Strategic Audit |
| 6 | PEGE870503D46 | PEREZ GAYTAN EDITH ADRIANA | 500-05-2025-5839 dated February 7, 2025 | Central Administration of Strategic Audit |
| 7 | PSS160421J24 | PRESTADORA DE SERVICIOS SKYNER, S.A. DE C.V. | 500-05-2025-5840 dated February 10, 2025 | Central Administration of Strategic Audit |
| 8 | SELB950111L47 | SERRANO LOPEZ BEATRIZ GUADALUPE | 500-05-2025-5841 dated February 10, 2025 | Central Administration of Strategic Audit |
| 9 | UUCS660303851 | URZUA CARTAGENA SOLEDAD | 500-05-2025-5842 dated February 10, 2025 | Central Administration of Strategic Audit |
Section E.- Additional data of the taxpayers.
| R.F.C. | Name, denomination or corporate name of the Taxpayer | Fiscal Address | Predominant Activity | Reason for the Procedure |
|---|---|---|---|---|
| 1 | LSC140728T18 | LOLMEX SOLUCIONES COMERCIALES, S.A. DE C.V. | Iztacalco, Mexico City | Other wholesale trade intermediaries |
| 2 | MCO131121869 | MACO CONCRETOS, S.A. DE C.V. | Tlanepantla de Baz, State of Mexico | Concrete manufacturing |
| 3 | MEB130710280 | MULTICOMERCIAL Y EMPRESARIAL BUSHRA, S.A. DE C.V. | Guadalupe, Nuevo León | Other business support services |
| 4 | MZO170829397 | MULTISERVICIOS ZORDIN, S.A. DE C.V. | Cuauhtémoc, Mexico City | Other professional, scientific and technical services |
| 5 | PAL201002KG5 | PALADIN ALIMENTOS, S.A. DE C.V. | Taxco de Alarcon, Guerrero | Wholesale trade of distilled agave beverages |
| 6 | PEGE870503D46 | PEREZ GAYTAN EDITH ADRIANA | Magdalena Contreras, Mexico City | Repair and maintenance of industrial machinery and equipment |
| 7 | PSS160421J24 | PRESTADORA DE SERVICIOS SKYNER, S.A. DE C.V. | Miguel Hidalgo, Mexico City | Other professional, scientific and technical services |
| 8 | SELB950111L47 | SERRANO LOPEZ BEATRIZ GUADALUPE | Culiacán, Sinaloa | Repair and maintenance of industrial machinery and equipment |
| 9 | UUCS660303851 | URZUA CARTAGENA SOLEDAD | Venustiano Carranza, Mexico City | Repair and maintenance of industrial machinery and equipment |
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