Notice 500-05-2025-20116 Communicating the Definitive Global List Under Article 69-B, Paragraph Four of the Federal Tax Code

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DOF: 01/08/2025

OFFICE 500-05-2025-20116 communicating the definitive global list under Article 69-B, paragraph four 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: 500-05-2025-20116

Subject:

Communicating the definitive global list under Article 69-B, paragraph four 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 the provisions of 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 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; 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, in effect from November 22, 2015, in accordance with the provisions of the first paragraph of the First Transitory Article of said Regulations and amended by Decree reforming and adding various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and 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 the provisions of 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, in effect from July 23, 2016, in accordance with the provisions of the First Transitory Article of said Agreement; as well as 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 authorities 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 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 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 referred to 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 of it.

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 of it, the foregoing in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax Code in effect, in relation to 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 the individual presumption notices, the tax authorities granted each taxpayer a period of fifteen business days counted from the last of the aforementioned notifications, to make the statements and provide the evidence they considered pertinent to rebut the facts made known through the aforementioned notices, warned that if, after the granted period, they did not provide the documentation and information and/or what they exhibited, once valued, did not rebut 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 the definitive individual resolution, as well as the publication of their names, denominations, or trade names in the list of taxpayers who did not rebut the facts made known and therefore, would be in a definitive situation referred to in the first paragraph of the aforementioned Article 69-B of the Federal Tax Code.

Once the period indicated in the previous 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 exercise of the right provided in the aforementioned 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 aforementioned individual notices, 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 manifested and proofs provided by those taxpayers, the aforementioned authorities considered that those taxpayers did not rebut the facts imputed to them in the individual presumption notices 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 aforementioned reasons, and taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code indicates 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, said period 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 the Third Resolutive 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 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 a definitive 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, a 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, to effect, with general effects, that the fiscal receipts issued by said taxpayers did not produce nor produced any fiscal effect whatsoever, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the foregoing, 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, June 26, 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.

Annex 1 of office number 500-05-2025-20116 dated June 26, 2025, corresponding to taxpayers who DID provide arguments and/or proofs, but DID NOT rebut the reason for which they were notified of the presumption notice, 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 NOTICE 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 trade name of the Taxpayer	Number and date of individual presumption notice	Issuing Authority of the individual presumption notice	Notification Medium to Taxpayer
				Authority's Estrados	Personal Notification	Tax Box Notification
				Date of fixation on the Estrados of the Fiscal Authority	Date on which notification took effect	Date of notification	Date on which notification took effect	Date of notification	Date on which notification took effect
1	DIS2109083Q9	DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V.	500-54-00-02-01-2024-3556 dated November 1, 2024	Disaggregated Administration of Fiscal Audit of Sonora "1"	November 4, 2024	November 5, 2024
2	NJT140516A28	NI JAU TEXTILES, S.A. DE C.V.	500-05-2020-23665 dated November 10, 2020	Central Administration of Strategic Audit	November 11, 2020	November 12, 2020
3	YUCA870221IF1	YUDICHE CONTRERAS ALAN	500-62-00-06-02-2024-3001 dated November 29, 2024	Disaggregated Administration of Fiscal Audit of Tamaulipas "5"	December 5, 2024	December 6, 2024

Section B.- Notification on the Internet page of the Tax Administration Service.

R.F.C.	Name, denomination or trade name of the Taxpayer	Number and date of global presumption notice	Issuing Authority of the global presumption notice	Date of notification on the Internet page of the Tax Administration Service	Date on which notification took effect
1	DIS2109083Q9	DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V.	500-05-2024-25842 dated November 11, 2024	Central Administration of Strategic Audit	November 11, 2024
2	NJT140516A28	NI JAU TEXTILES, S.A. DE C.V.	500-05-2020-28756 dated December 1, 2020	Central Administration of Strategic Audit	December 1, 2020
3	YUCA870221IF1	YUDICHE CONTRERAS ALAN	500-05-2024-26177 dated December 13, 2024	Central Administration of Strategic Audit	December 13, 2024

Section C.- Notification in the Official Gazette of the Federation.

R.F.C.	Name, denomination or trade name of the Taxpayer	Number and date of global presumption notice	Issuing Authority of the global presumption notice	Date of notification in the Official Gazette of the Federation	Date on which notification took effect
1	DIS2109083Q9	DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V.	500-05-2024-25842 dated November 11, 2024	Central Administration of Strategic Audit	January 24, 2025
2	NJT140516A28	NI JAU TEXTILES, S.A. DE C.V.	500-05-2021-5056 dated February 9, 2021	Central Administration of Strategic Audit	February 23, 2021
3	YUCA870221IF1	YUDICHE CONTRERAS ALAN	500-05-2024-26177 dated December 13, 2024	Central Administration of Strategic Audit	January 24, 2025

Section D.- Notification of the DEFINITIVE RESOLUTION notice in accordance with the fourth paragraph of Article 69-B of the Federal Tax Code.

R.F.C.	Name, denomination or trade name of the Taxpayer	Number and date of definitive resolution	Issuing Authority of the definitive resolution	Notification Medium to Taxpayer
				Authority's Estrados	Personal Notification	Tax Box Notification
				Date of fixation on the Estrados of the Fiscal Authority	Date on which notification took effect	Date of notification	Date on which notification took effect	Date of notification	Date on which notification took effect
1	DIS2109083Q9	DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V.	500-54-00-02-01-2025-1669 dated May 6, 2025	Disaggregated Administration of Fiscal Audit of Sonora "1"	May 7, 2025	May 8, 2025
2	NJT140516A28	NI JAU TEXTILES, S.A. DE C.V.	In compliance with what was resolved by the Disaggregated Juridical Administration of Mexico "2", within the Revocation Appeal RRL2021007829	500-05-2025-12262 dated April 23, 2025	Central Administration of Strategic Audit	April 29, 2025	April 30, 2025
3	YUCA870221IF1	YUDICHE CONTRERAS ALAN	500-62-00-06-02-2025-1161 dated March 26, 2025	Disaggregated Administration of Fiscal Audit of Tamaulipas "5"	March 27, 2025	March 28, 2025

Section E.- Additional data of the taxpayers.

R.F.C.	Name, denomination or trade name of the Taxpayer	Fiscal Address	Predominant Activity	Reason for the Procedure
1	DIS2109083Q9	DOBEL INGENIERIAS Y SERVICIO, S.A. DE C.V.	HERMOSILLO, SONORA	CONSTRUCTION OF COMMERCIAL, INSTITUTIONAL AND SERVICE BUILDINGS
2	NJT140516A28	NI JAU TEXTILES, S.A. DE C.V.	TULTITLAN, STATE OF MEXICO	WHOLESALE TRADE OF WHITE GOODS
3	YUCA870221IF1	YUDICHE CONTRERAS ALAN	TAMPICO, TAMAULIPAS	CONSTRUCTION OF COMMERCIAL, INSTITUTIONAL AND SERVICE BUILDINGS, CONSTRUCTION OF MARITIME, RIVERINE AND SUBAQUATIC WORKS, OTHER CIVIL ENGINEERING CONSTRUCTIONS OR HEAVY WORK

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