Notice 500-05-2025-12328 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code

DOF: 11/07/2025

OFFICE 500-05-2025-12328 through which a 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, valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.

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

Central Administration of Strategic Auditing.

OFFICE: 500-05-2025-12328

Subject: List of taxpayers who

promoted some means of defense against the

presumption notice referred to in Article 69-B first

paragraph of the CFF, valid until July 24, 2018, or

against the resolution referred to in the third paragraph

of the aforementioned article, and once resolved, the

jurisdictional or administrative body left unsubstantiated the

referred act.

This Central Administration of Strategic Auditing, 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, reformed by Decree published in the same Official Gazette on

June 12, 2003; 1, 2, first and second 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, 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

conformity with what is established in 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 Customs Agency of

Mexico are issued, published in the same official organ on December 21, 2021, effective from January 01,

2022, in conformity with what is established in 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 Federation on June 23,

2016, effective from July 23, 2016, in conformity with what is established in the First Transitory

Article of said Agreement; in articles 33, last paragraph, 63 and 69-B, first and second paragraphs of the

Federal Tax Code valid 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 Federation on June 25, 2018 and Eighth Transitory Article, fraction IV,

of the Fiscal Miscellany Resolution for 2025, published in the Official Gazette of the Federation on December 30,

2024, informs you as follows:

That to the taxpayers listed below, at the time, they were notified of an Office of

Presumption of non-existence of operations supported by certain fiscal receipts that

they issued, this in accordance with the first and second paragraphs of Article 69-B of the Federal Tax Code

valid until July 24, 2018, in relation to Article 69 of its Regulations.

Following the procedure provided for in the aforementioned Article 69-B of the Federal Tax Code, valid

until July 24, 2018, and in terms of the third paragraph of the aforementioned article, to the taxpayers of

reference was notified the definitive resolution as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

R.F.C.

Name, denomination

or trade name of the

Taxpayer

Number and date of

office of definitive

resolution

Means of notification to the taxpayer

Authority's public notice

Personal Notification

Tax Box

Date of fixation

on the public notice

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

01

GRE120330M68

GUPA

REFRIGERACION, S.

DE R.L. DE C.V.

500-35-00-06-01-

2018-2167 dated

February 15, 2018

February 22, 2018

March 19, 2018

02

IMA040423F47

INMOBILIARIA

MACADAM, S.A. DE

C.V.

500-05-2017-38571

dated October 18,

2017

October 24,

2017

October 25,

2017

03

JDE100419HT0

JR DINAMICA

EMPRESARIAL S.A. DE

C.V.

500-05-2015-33864

dated November 27,

2015

February 08, 2016

March 02, 2016

04

TFI050606PD7

TECNICA FINANCIERA,

S.C.

500-43-03-07-01-

2018-2687 dated

March 22, 2018

April 05, 2018

April 06, 2018

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or trade

name of the Taxpayer

Fiscal Address

Preponderant Activity

Reason for the Procedure

01

GRE120330M68

GUPA REFRIGERACION, S. DE

R.L. DE C.V.

TOLUCA, STATE OF

MEXICO

MANUFACTURING AND ASSEMBLY OF

INDUSTRIAL AND COMMERCIAL REFRIGERATION SYSTEMS

Absence of assets,

Absence of personnel, Lack

of infrastructure

02

IMA040423F47

INMOBILIARIA MACADAM, S.A.

DE C.V.

SALTILLO, COAHUILA DE

ZARAGOZA

CONSTRUCTION OF COMMERCIAL, INSTITUTIONAL AND SERVICE REAL ESTATE

Absence of assets,

Absence of personnel

03

JDE100419HT0

JR DINAMICA EMPRESARIAL S.A.

DE C.V.

ZAPOPAN, JALISCO

BUSINESS ADMINISTRATION SERVICES

Absence of assets,

Absence of personnel, Lack

of infrastructure, No

material capacity

04

TFI050606PD7

TECNICA FINANCIERA, S.C.

SAN PEDRO GARZA

GARCIA, NUEVO LEON

INSTITUTIONS FOR THE DEPOSIT OF

SECURITIES

Absence of assets,

Absence of personnel

For the above, the name or trade name of the taxpayers

to whom the aforementioned

resolutions were notified, were added to the list referred to in the third paragraph of Article 69-B of the Federal Tax

Code, valid until July 24, 2018, which was published in the Official Gazette of the

Federation, as indicated below:

No.

R.F.C.

Name or trade name of the

Taxpayer

Number and date of office containing in Global Definitive List

Date of publication in the Official

Gazette of the Federation

01

GRE120330M68

GUPA REFRIGERACION, S. DE R.L. DE C.V.

500-05-2018-14369 dated June 22, 2018

July 20, 2018

02

IMA040423F47

INMOBILIARIA MACADAM, S.A. DE C.V.

500-05-2017-38777 dated December 15, 2017

January 03, 2018

03

JDE100419HT0

JR DINAMICA EMPRESARIAL S.A. DE C.V.

500-05-2016-15905 dated May 16, 2016

May 30, 2016

04

TFI050606PD7

TECNICA FINANCIERA, S.C.

500-05-2018-20842 dated July 12, 2018

August 21, 2018

Disagreeing with the individual presumption office or definitive resolution office, they filed means of

defense, which concluded with the following resolution or sentence:

No.

R.F.C.

Name or trade

name of the Taxpayer

Means of defense

Date of the

Resolution or

final sentence

Authority that resolved

Sense and/or effect of the

final resolution or sentence

01

GRE120330M68

GUPA REFRIGERACION, S. DE

R.L. DE C.V.

Nullity Trial 358/22-29-01-3

April 22, 2024

Regional South Court of

State of Mexico and Auxiliary

of the Federal Tribunal of

Administrative Justice

The nullity of the

challenged resolution 500- 35-00-06-01-2018-2167 of

February 15, 2018,

issued by the

Decentralized Administration of

Fiscal Audit of Mexico

"1".

02

IMA040423F47

INMOBILIARIA MACADAM, S.A.

DE C.V.

Nullity Trial 65/21-05-02-9

February 21, 2023

Second Regional North Court

Center II of the Federal Tribunal of

Administrative Justice

The nullity of the

challenged resolution 500- 05-2017-38571 dated October 18

2017, issued

by the Central Administration of Strategic

Auditing.

03

JDE100419HT0

JR DINAMICA EMPRESARIAL

S.A. DE C.V.

Nullity Trial 9257/21-07-03-5

January 05, 2024

Third Regional Western Court

of the Federal Tribunal of

Administrative Justice

The nullity of the

challenged resolution 500-05-2015- 33864 of November 27

2015, issued by the

Central Administration of

Strategic Auditing.

04

TFI050606PD7

TECNICA FINANCIERA, S.C.

Online Revocation Appeal

RRL2018004549

November 20, 2018

Decentralized Legal Administration

of Nuevo Leon "3", of the

General Legal

Administration

The resolution 500-43-03-07-01- 2018-2687 of March 22

2018, issued by the

Decentralized Administration of

Fiscal Audit of Nuevo

Leon "3", is left unsubstantiated, and it is ordered to issue

a new resolution in accordance with what was resolved

in point I of the Section

of "reasons for the

resolution".

In view of the above, it is communicated that, as a consequence of the means of defense indicated

in the preceding paragraph, the procedure of Article 69-B of the Federal Tax Code valid until

July 24, 2018, followed against those taxpayers, has become 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 supported such receipts, for which, the powers of

the tax authority are reserved.

Sincerely.

Mexico City, May 06, 2025.- In substitution for the absence of the Central Administrator of

Strategic Auditing, of the Coordinator of Strategic Auditing, of the Administrator of Strategic

Auditing "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 Hernandez, Administrator of Strategic Auditing "7".- Rubric.

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