Regulatory Alerts2025-07-11 | DOF 5762721Added
Notice 500-05-2025-12329 Communicating the List of Taxpayers Who Filed Legal Defenses Against Presumption Notices or Resolutions Under Article 69-B of the Federal Tax Code, Resulting in the Annulment of the Administrative Act
The document announces that the tax procedures initiated against twelve specific taxpayers under Article 69-B of the Federal Tax Code have been rendered without effect. This outcome follows final judicial rulings that declared null and void the presumption notices and definitive resolutions previously issued against these entities. The affected taxpayers are listed with their tax identification numbers, the specific legal defenses filed, and the dates of the court decisions that annulled the administrative acts. The tax authority reserves its right to investigate other fiscal documents issued by these taxpayers that may lack the necessary assets, personnel, or infrastructure to support the services or goods declared.
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DOF: 11/07/2025
OFFICE 500-05-2025-12329 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 jurisdictional or administrative body left the referred act without effect.
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: 500-05-2025-12329
Subject: Communication of the list of taxpayers who
promoted some means of defense against the notice
of presumption referred to in Article 69-B first
paragraph of the CFF or against the resolution referred to in the
fourth paragraph of the aforementioned article, and once
resolved, the jurisdictional or
administrative body left the referred act without effect.
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
december 15, 1995, reformed by Decree published in the same Official Gazette 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, numeral 5 of the Internal Regulations of the Tax Administration Service, published in the Official
Gazette of the Federation on August 24, 2015, in force from November 22, 2015, in
conformity with what is established in the first paragraph of the First Transitory Article of said Regulations, and
reformed through Decree by which various provisions of the Internal Regulations of the Ministry of Treasury and Public Credit and of the Internal Regulations of the Service
of Tax Administration 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 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 force 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, sixth paragraph of the Fiscal Code of the
Federation, communicates the following:
That to the taxpayers listed below, at some point, a Notice of
Presumption of non-existence of operations backed by certain fiscal receipts that
they issued was notified, this in accordance with the first and second paragraphs of Article 69-B of the Fiscal Code of the
Federation, in relation to Article 69 of its Regulations.
Following the procedure provided for in the aforementioned Article 69-B of the Fiscal Code of the Federation, and in
terms of the fourth paragraph of the aforementioned article, the aforementioned taxpayers 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 trade name of the
Taxpayer
Number and date
of office of
definitive resolution
Means of notification to the taxpayer
Authority's files
Personal Notification
Tax Box
Date of fixation
on the files
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
BEN110409BI1
BENEDYKS, S.A. DE
C.V.
500-44-00-00-00-
2019-08727 of
date October 31,
2019
08 of
November
2019
11 of
November
2019
02
CAME721204BR8
CAMACHO MARQUEZ
EDGAR
500-35-00-06-01-
2019-13455 of
date July 10, 2019
July 29, 2019
July 30, 2019
03
CAN120120EG9
COORDINACION
AVANZADA DE
NEGOCIOS, S.A. DE
C.V.
500-05-2021-5185
of date February 23,
2021
February 26, 2021
March 10, 2021
04
CEC0602282P8
CONGRESOS Y
EVENTOS
CULTURALES, S.A. DE
C.V.
500-46-00-05-02-
2020-17587 of
date September 04,
2020
September 09,
2020
September 10,
2020
05
FCO181218DX8
FRANCISCA
CONSULTING, S.A. DE
C.V.
500-05-2020-4912
of date January 14,
2021
January 14,
2021
January 15, 2021
06
FLE1501282A0
FLEXOMERK, S.C.
500-55-00-03-00-
2019-794 of date
February 22, 2019
October 24,
2024
October 25,
2024
07
NEM160617M67
NJEREZ
EMPLOYMENT, S.A. DE
C.V.
500-05-2021-5019
of date February 15,
2021
February 15,
2021
February 16,
2021
08
OPA130718199
OPERADORA DE
PERSONAL ALFA, S.
DE R.L. DE C.V.
500-36-07-01-02-
2021-5422 of
date May 13, 2021
June 01, 2021
June 02, 2021
09
SIV180514MF6
SERVICIOS
INTEGRALES VABOK,
S.A. DE C.V.
500-05-2023-4126
of date March 03,
2023
March 09,
2023
March 10, 2023
10
SNT140523B85
SOLIDARIDAD CON
LAS NECESIDADES DE
LOS TRABAJADORES,
S.A. DE C.V.
500-05-2021-
27579 of date August 20,
2021
August 26,
2021
August 27, 2021
11
TSE110609IK2
TENOCHTITLAN
SOLUCIONES
EMPRESARIALES, S.A.
DE C.V.
500-44-00-00-00-
2021-07367 of
date September 23,
2021
September 27,
2021
September 28,
2021
12
TCO160616L43
TITAARIA
CONSULTORES, S.A.
DE C.V.
500-05-2021-4886
of date January 14,
2021
January 14,
2021
January 15, 2021
Additional data of the taxpayers.
No.
R.F.C.
Name, denomination or trade name of the
Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
01
BEN110409BI1
BENEDYKS, S.A. DE C.V.
OAXACA DE JUÁREZ,
OAXACA
OTHER CIVIL ENGINEERING CONSTRUCTIONS
OR HEAVY WORK
Absence of assets,
Absence of personnel
02
CAME721204BR8
CAMACHO MARQUEZ EDGAR
METEPEC, ESTADO DE
MÉXICO
ENVIRONMENTAL CONSULTING SERVICES
Absence of assets,
Absence of personnel
03
CAN120120EG9
COORDINACION AVANZADA DE NEGOCIOS,
S.A. DE C.V.
BENITO JUÁREZ, QUINTANA
ROO
SUPPORT SERVICES TO CARRY OUT
LEGAL PROCEDURES
Absence of assets,
Absence of personnel
04
CEC0602282P8
CONGRESOS Y EVENTOS CULTURALES, S.A.
DE C.V.
GUADALAJARA, JALISCO
OTHER ADVERTISING SERVICES
Absence of assets,
Absence of personnel, Without
material capacity
05
FCO181218DX8
FRANCISCA CONSULTING, S.A. DE C.V.
BENITO JUÁREZ, QUINTANA
ROO
ADMINISTRATION CONSULTING SERVICES
Absence of assets,
Absence of personnel
06
FLE1501282A0
FLEXOMERK, S.C.
ZAPOPAN, JALISCO
BUSINESS ADMINISTRATION SERVICES
Absence of assets,
Absence of personnel
07
NEM160617M67
NJEREZ EMPLOYMENT, S.A. DE C.V.
BENITO JUÁREZ, QUINTANA
ROO
ADMINISTRATION CONSULTING SERVICES
Absence of assets,
Absence of personnel
08
OPA130718199
OPERADORA DE PERSONAL ALFA, S. DE R.L.
DE C.V.
MAZATLÁN, SINALOA
ACCOUNTING SERVICES,
AUDIT AND ACCOUNTING AND
FISCAL ADVISORY
Absence of assets, Lack
of infrastructure, Without
material capacity
09
SIV180514MF6
SERVICIOS INTEGRALES VABOK, S.A. DE
C.V.
HERMOSILLO, SONORA
OTHER RETAIL TRADE INTERMEDIARIES
Absence of assets,
Absence of personnel
10
SNT140523B85
SOLIDARIDAD CON LAS NECESIDADES DE
LOS TRABAJADORES, S.A. DE C.V.
ALCALDÍA GUSTAVO A.
MADERO, CIUDAD DE
MÉXICO
ADMINISTRATION CONSULTING SERVICES
Absence of assets,
Absence of personnel
11
TSE110609IK2
TENOCHTITLAN SOLUCIONES
EMPRESARIALES, S.A. DE C.V.
OAXACA DE JUÁREZ,
OAXACA
ACCOUNTING AND AUDIT SERVICES
Absence of assets,
Absence of personnel, Lack
of infrastructure, Without
material capacity
12
TCO160616L43
TITAARIA CONSULTORES, S.A. DE C.V.
BENITO JUÁREZ, QUINTANA
ROO
HOTELS WITH OTHER INTEGRATED SERVICES
Absence of assets,
Absence of personnel
Therefore, the name or trade 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 Fiscal Code
of the Federation, which was published in the Official Gazette of the Federation, as indicated below:
No.
R.F.C.
Name, denomination or trade name of the
Taxpayer
Number and date of office containing in List
Global Definitivo
Date of publication in the Official
Gazette of the Federation
01
BEN110409BI1
BENEDYKS, S.A. DE C.V.
500-05-2020-3645 of date January 15, 2020
February 14, 2020
02
CAME721204BR8
CAMACHO MARQUEZ EDGAR
500-05-2019-27927 of date September 25, 2019
October 25, 2019
03
CAN120120EG9
COORDINACION AVANZADA DE NEGOCIOS, S.A. DE
C.V.
500-05-2021-15156 of date May 25, 2021
June 08, 2021
04
CEC0602282P8
CONGRESOS Y EVENTOS CULTURALES, S.A. DE
C.V.
500-05-2021-5055 of date February 09, 2021
February 22, 2021
05
FCO181218DX8
FRANCISCA CONSULTING, S.A. DE C.V.
500-05-2021-5303 of date March 04, 2021
March 18, 2021
06
FLE1501282A0
FLEXOMERK, S.C.
500-05-2019-27749 of date August 27, 2019
September 25, 2019
07
NEM160617M67
NJEREZ EMPLOYMENT, S.A. DE C.V.
500-05-2021-6937 of date April 26, 2021
May 13, 2021
08
OPA130718199
OPERADORA DE PERSONAL ALFA, S. DE R.L. DE
C.V.
500-05-2021-15538 of date July 15, 2021
August 18, 2021
09
SIV180514MF6
SERVICIOS INTEGRALES VABOK, S.A. DE
C.V.
500-05-2023-21167 of date August 28, 2023
September 26, 2023
10
SNT140523B85
SOLIDARIDAD CON LAS NECESIDADES DE LOS
TRABAJADORES, S.A. DE C.V.
500-05-2021-26136 of date October 25, 2021
November 10, 2021
11
TSE110609IK2
TENOCHTITLAN SOLUCIONES EMPRESARIALES,
S.A. DE C.V.
500-05-2021-26246 of date November 25, 2021
December 15, 2021
12
TCO160616L43
TITAARIA CONSULTORES, S.A. DE C.V.
500-05-2021-5303 of date March 04, 2021
March 18, 2021
Dissatisfied with the individual presumption notice or definitive resolution notice, they filed means of
defense, which were concluded with the following resolutions or sentences:
No.
R.F.C.
Name, denomination 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 resolution or
final sentence
01
BEN110409BI1
BENEDYKS, S.A. DE C.V.
Nullity Trial 127/20-
15-01-2
February 04, 2025
Regional Court of
the Southeast of the Federal Court of Administrative Justice
The nullity of the challenged resolution 500-44-00-00-00- 2019-08727 of date October 31, 2019, issued by the Decentralized Administration of Fiscal Audit of Oaxaca "1" is declared.
02
CAME721204BR8
CAMACHO MARQUEZ EDGAR
Nullity Trial 966/19-
29-01-4
May 04, 2021
Southern Regional Court of the State of Mexico and
Auxiliary of the Federal Court of Administrative Justice
The nullity of the challenged resolution 500-35-00-06-01-2019-13455
of date July 10, 2019, issued by the
Decentralized Administration of Fiscal Audit of Mexico "1" is declared.
03
CAN120120EG9
COORDINACION AVANZADA DE
NEGOCIOS, S.A. DE C.V.
Nullity Trial 886/22-
02-01-4
March 11, 2024
Regional Court of
Northwest II of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 600-49-2022-615 of
date March 01, 2022, issued by the
Decentralized Juridical Administration of Quintana Roo "2", through which,
it resolved the Online Administrative Revocation Appeal RRL2021004985, as
well as, the originally challenged 500- 05-2021-5185 of February 23, 2021,
issued by the Central Administration of Strategic Auditing.
04
CEC0602282P8
CONGRESOS Y EVENTOS
CULTURALES, S.A. DE C.V.
Nullity Trial 2626/21-
07-01-9
August 01, 2023
First Regional Court
of the West of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 600-46-00-04-00-2021-411 of
January 22, 2021, issued by the
Decentralized Juridical Administration of Puebla "2", by which, it resolved the
Online Administrative Revocation Appeal
RRL2020008980, as well as, the
originally challenged 500-46-00-05-02- 2020-17587 of date September 04,
2020, issued by the Decentralized Administration of Fiscal Audit of
Puebla "2" is declared.
05
FCO181218DX8
FRANCISCA CONSULTING, S.A.
DE C.V.
Nullity Trial 1128/21-
02-01-2
and its accumulation
1937/21-02-01-6
January 23, 2023
Regional Court of
Northeast II of the Federal
Court of Administrative Justice
The nullity of the fictitious confirmation attributed to the
Decentralized Juridical Administration of Quintana Roo "2", regarding the Online Administrative Revocation Appeal
RRL2021002343, as well as, the
originally challenged 500-05-2020-4912
of January 14, 2021, issued by the
Central Administration of Strategic Auditing is declared.
06
FLE1501282A0
FLEXOMERK, S.C.
Nullity Trial 2470/20-
03-02-2
February 17, 2023
Regional Court of
North Center IV and
Auxiliary of the Federal
Court of Administrative Justice
The nullity of the challenged resolution 600-32-2019-06846 of date
October 29, 2019, issued by the
Decentralized Juridical Administration of Jalisco "3", by which, it resolves the
Online Revocation Appeal
RRL2019003254, as well as, of the
originally challenged 500-55-00-03-00- 2019-794 of February 22, 2019,
issued by the Decentralized Administration of Fiscal Audit of Sonora "2", for the effect that the
Decentralized Administration of Fiscal Audit of Sonora "2", [ ... ] in
freedom of jurisdiction issues a new resolution in terms of the fourth paragraph
of Article 69-B, of the Federal Tax Code [ ... ].
07
NEM160617M67
NJEREZ EMPLOYMENT, S.A. DE
C.V.
Nullity Trial 203/23-
02-01-9
December 04, 2023
Regional Court of
Northwest II of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 600-49-2022- 003762 of date November 15, 2022,
issued by the Decentralized Juridical Administration of Quintana Roo
"2", which resolves the Online Administrative Revocation Appeal
RRL2021004185, as well as, of the
originally challenged 500-05-2021-5019
of February 15, 2021, issued by the
Central Administration of Strategic Auditing is declared.
08
OPA130718199
OPERADORA DE PERSONAL
ALFA, S. DE R.L. DE C.V.
Nullity Trial 3802/21-
03-01-9
June 23, 2023
First Regional Court
of Northwest III of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 500-36-07-01-02-2021-5422
of date May 13, 2021, issued by the
Decentralized Administration of Fiscal Audit of Mexico "2" is declared.
09
SIV180514MF6
SERVICIOS INTEGRALES
VABOK, S.A. DE C.V.
Nullity Trial 1126/23-
02-01-6
May 20, 2024
Regional Court of
Northwest II of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 500-05-2023-4126 of date March 03,
2023, issued by the
Central Administration of Strategic Auditing is declared.
10
SNT140523B85
SOLIDARIDAD CON LAS
NECESIDADES DE LOS
TRABAJADORES, S.A. DE C.V.
Nullity Trial 2944/21-
11-01-4
March 01, 2023
First Regional Court
North-East of the State
of Mexico of the Federal Court of Administrative Justice
The nullity of the challenged resolution 500-05-2021-27579
of date August 20, 2021, issued by
the Central Administration of Strategic Auditing is declared.
11
TSE110609IK2
TENOCHTITLAN SOLUCIONES
EMPRESARIALES, S.A. DE C.V.
Nullity Trial 2359/21-
15-01-2
May 20, 2024
Regional Court of
the Southeast of the Federal
Court of Administrative Justice
The nullity of the challenged resolution 500-44-00-00-00-2021-07367
of date September 23, 2021,
issued by the Decentralized Administration of Fiscal Audit
Oaxaca "1" is declared.
12
TCO160616L43
TITAARIA CONSULTORES, S.A.
DE C.V.
Nullity Trial 1130/21-
02-01-5
December 02, 2022
Regional Court of
Northwest II of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 600-49-2021-2703 of date September 20, 2021,
issued by the Decentralized Juridical Administration of Quintana Roo
"2", which resolved the Online Administrative Revocation
Appeal RRL2021002344, as well as, of the originally challenged
500-05-2021-4886 of January 14, 2021,
issued by the Central Administration of Strategic Auditing is declared.
In view of the above, it is communicated that, as a consequence of the means of defense indicated
in preceding paragraphs, the procedure of Article 69-B of the Fiscal Code of the Federation, followed by
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 liability
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, 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 Hernández, Administrator of Strategic Auditing "7".- Rubric.
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