2025-09-12 | DOF 5767842Added
The Strategic Fiscal Audit Central Administration adds two taxpayers to the definitive global list of contributors who failed to rebut facts regarding the issuance of fiscal receipts without sufficient assets, personnel, infrastructure, or material capacity. The affected entities are DL Services and Maintenance, S. de R.L. de C.V., and Velazquez Rizo Rodrigo. Consequently, fiscal receipts issued by these contributors are declared to have produced no fiscal effect whatsoever.
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DOF: 12/09/2025
OFFICE 500-05-2025-20321 communicating the final global list in terms of article 69-B, fourth paragraph of the Federal Tax Code
At the margin a seal with the National Coat of Arms, which says: 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: 500-05-2025-20321
Subject:
Communicating final global list in terms of 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 provided for in 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 of
the Federation on June 12, 2003; 1, 2, paragraphs first, section B,
fraction III, subsection e), and second, 5, first paragraph, 13, fraction VI, 23, section E, fraction I, in relation with article
22
paragraphs first, 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 provided for 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
Finance 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 Agency of Customs
of Mexico are issued, published in the same official organ on December 21
2021, effective from January 01
2022, in conformity with what is provided for in the First Transitory Article of
said Decree; Third Article, fraction I, subsection a), of the Agreement by which various attributions 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 provided for in the First Transitory Article of
said Agreement; as well as in articles 33, last paragraph, 63, and 69-B paragraphs first, fourth and fifth of the Fiscal Code of
the Federation, notifies the following:
As a result of the exercise of the attributions and powers indicated in article 69-B, paragraphs first and second 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 cited 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.
Detected such situation, the tax authority, in order to comply with article 69-B, paragraph second, of the Federal Tax
Code, as well as numeral 69 of the Regulations of said Code, issued individual presumption office to each one of the
taxpayers mentioned in the cited Annex 1, and in said office
it indicated the reasons and grounds 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 offices 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,
section B and C, of this present office, which is an integral part of it, 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 with the
article 135 of the Federal Tax Code.
Attending what is provided for by the second paragraph of article 69-B of the Federal Tax Code, in the offices of
individual presumption the tax authorities granted each taxpayer a term of fifteen business days counted from
the last of the notifications previously made, so that they could make the manifestations and provide the proofs
that they considered pertinent to disprove the facts given known through the cited offices, warned that if
after the granted term they did not provide
the documentation and information and/or that they exhibited, once valued, did not
disprove the facts indicated in the merit offices, 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 individual definitive resolution,
as well as the publication of their names, denominations or trade names in the list of taxpayers who
did not disprove the facts given known and therefore, they would be in definitive form in the situation referred to the
first paragraph of said article 69-B of the Federal Tax Code.
Once the term indicated in the previous paragraph has passed, and in virtue that those taxpayers during the term
established in the second paragraph of article 69-B of the Federal Tax Code, in exercise of the right provided for in
said legal provision, presented, through the means indicated in the individual resolutions themselves, diverse
information, documentation and arguments in order to disprove the facts given known in the individual offices
indicated above, 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 referred authorities considered that those taxpayers did not
disprove the facts that were attributed to them in the individual offices of presumption 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 disprove said facts; resolutions that were duly notified in the terms
indicated in the paragraphs preceding each one of the taxpayers indicated in Annex 1, section D, of
this present office.
For the aforementioned and, taking into account that the fourth paragraph of article 69-B of the Federal Tax
Code, indicates that under no circumstances will the list be published before thirty business days after the notification
of the resolution and that, at the date said term has elapsed since the notification of the resolution and, also the cited
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 , that has been initiated against them; therefore, with the purpose of giving full compliance to Resolutive Third contained
in the cited definitive resolutions, this Central Administration of Strategic Audit, attached to the Administration
General of Federal Fiscal Audit of the Tax Administration Service, in support of the tax authorities indicated
in Annex 1 of this present, proceeds to add the names, denominations or trade names of the taxpayers
indicated in Annex 1 of this present office, in the list of taxpayers who did not disprove the facts that were attributed to them
and therefore, they are in definitive form in the situation referred to in the first paragraph of said article
69-B of the Federal Tax Code , for the reasons and grounds indicated in the definitive resolutions notified
to each one 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, to effect considering, with general effects, that the
fiscal receipts issued by said taxpayers did not produce nor produced any fiscal effect whatsoever, such as it is
declared by the fifth paragraph of article 69-B of the Federal Tax Code; the above, inasmuch as it is of public interest
that the billing of non-existent operations be stopped, as well as that society knows who those
taxpayers who carry out this type of operations are.
Sincerely.
Mexico City, July 17, 2025. - Central Administrator of Strategic Audit , L.C. Rubén Martín López
Rodríguez .- Rubric.
.
Annex 1 of office number 500-05-2025-20321 dated July 17, 2025, corresponding to taxpayers who DID
provide arguments and/or proofs, but DID NOT disprove the reason for which the presumption office was notified to them,
updating DEFINITIVELY the situation referred to in the first paragraph of article 69-B of the Federal Tax Code
Section A.- Notification of PRESUMPTION OFFICE according to paragraphs first and second of article
69-B of the Federal Tax Code, in relation with article 69 of its Regulations.
R.F.C.
Name, denomination
or trade name of the
Taxpayer
Number and date of
individual office of
presumption
Issuing Authority
of the individual office
of presumption
Means of notification to the taxpayer
Authority's records
Personal notification
Notification by Tax Box
Date of
fixing in the
records of the
Fiscal Authority
Date when
notification took effect
Date of
notification
Date when
notification took effect
Date of
notification
Date when
notification took effect
1
DSM180813P99
DL SERVICES AND
MAINTENANCE, S. DE
R.L. DE C.V.
500-62-00-06-01-
2024-3174 dated
December 11
2024
Administration
Deconcentrated of
Fiscal Audit of
Tamaulipas "5"
December 13
2024
December 16
2024
2
VERR770415KQ9
VELAZQUEZ RIZO
RODRIGO
500-36-07-01-03-
2024-17028 dated
December 04
2024
Administration
Deconcentrated of
Fiscal Audit of
Mexico "2"
December 04
2024
December 05
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 office
of presumption
Issuing Authority of the global office
of presumption
Date of notification on the
internet page of the Service
of Tax Administration
Date when notification took effect
1
DSM180813P99
DL SERVICES AND
MAINTENANCE, S. DE R.L. DE C.V.
500-05-2025-5663 dated January 13
2025
Central Administration of
Strategic Audit
January 13, 2025
January 14, 2025
2
VERR770415KQ9
VELAZQUEZ RIZO RODRIGO
500-05-2024-26177 dated December 13
2024
Central Administration of
Strategic Audit
December 13, 2024
December 16, 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 office
of presumption
Issuing Authority of the global office
of presumption
Date of notification in the
Official Gazette of the Federation
Date when notification took effect
1
DSM180813P99
DL SERVICES AND
MAINTENANCE, S. DE R.L. DE C.V.
500-05-2025-5663 dated January 13
2025
Central Administration of
Strategic Audit
February 14, 2025
February 17, 2025
2
VERR770415KQ9
VELAZQUEZ RIZO RODRIGO
500-05-2024-26177 dated December 13
2024
Central Administration of
Strategic Audit
January 24, 2025
January 27, 2025
Section D.- Notification of the definitive RESOLUTION office according to 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
Means of notification to the taxpayer
Authority's records
Personal notification
Notification by Tax Box
Date of
fixing in
the records
of the
Fiscal Authority
Date when
notification took effect
Date of
notification
Date when
notification took effect
Date of
notification
Date when
notification took effect
1
DSM180813P99
DL SERVICES AND
MAINTENANCE, S.
DE R.L. DE
C.V.
500-62-00-06-01-
2025-1247 dated
April 16, 2025
Administration
Deconcentrated
of Fiscal Audit
of Tamaulipas "5"
April 24, 2025
April 25, 2025
2
VERR770415KQ9
VELAZQUEZ RIZO
RODRIGO
500-36-07-01-03-
2025-4626 dated
April 08, 2025
Administration
Deconcentrated
of Fiscal Audit
of Mexico "2"
April 08, 2025
April 09, 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
DSM180813P99
DL SERVICES AND
MAINTENANCE, S. DE R.L. DE
C.V.
ALTAMIRA, TAMAULIPAS
WHOLESALE TRADE OF METALLIC WASTE
ABSENCE OF ASSETS, ABSENCE OF
PERSONNEL, LACK OF INFRASTRUCTURE,
WITHOUT MATERIAL CAPACITY
2
VERR770415KQ9
VELAZQUEZ RIZO RODRIGO
ECATEPEC DE MORELOS,
STATE OF MEXICO
MANAGEMENT OF NON-HAZARDOUS WASTE AND
REMEDIATION SERVICES FOR DAMAGED AREAS
BY NON-HAZARDOUS WASTE
ABSENCE OF ASSETS, ABSENCE OF
PERSONNEL, LACK OF INFRASTRUCTURE,
WITHOUT MATERIAL CAPACITY
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