Notice 500-05-2025-20450 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code — SHCP — MX

DOF: 03/10/2025

OFFICE 500-05-2025-20450 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, 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.

A seal with the National Coat of Arms is placed at the margin, 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 Audit.

OFFICE: 500-05-2025-20450

Subject: Communication of the 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 the referred act unsubstantiated.

This Central Administration of Strategic Audit, 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 and second paragraphs, section B, fraction III, subsection e) and second, 5, first paragraph,

13, fraction VI, 23, section E, fraction I, in relation with 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 effect 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 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, in effect 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 attributes are delegated to the 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 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 with 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, communicates the following to you:

That to the taxpayers listed below, at the time, a Notice of

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

they issued was notified to them, 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 with 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 mentioned article, to the taxpayers of

reference, the definitive resolution was notified as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

R.F.C.

Name,

denomination or corporate name of the

Taxpayer

Number and date of

definitive resolution office

Means of notification to the taxpayer

Authority's public notice

Personal Notification

Tax Box

Date of posting

on the authority's

public notice

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

BRI131216PG6

BRIJ, S.C. DE S. DE

R.L. DE C.V.

500-72-03-01-2018-

12602 dated August 31,

2018

September 12,

2018

September 13,

2018

CAR160229F29

CARYRA, S. DE R.L.

DE C.V.

500-10-00-06-01-

2018-07642 dated

February 06, 2018

February 13, 2018

February 14,

2018

CGI150128J25

COMERCIALIZADORA

GIBRANTE, S.A. DE

C.V.

500-31-00-04-01-

2018-12154 dated

February 08, 2018

February 16, 2018

February 19,

2018

CKU120906LY6

COMERCIALIZADORA

KUMMILTO, S.A. DE

C.V.

500-70-00-05-03-

2018-08619 dated

August 02, 2018

August 16, 2018

September 10,

2018

CON0812224Q1

CONSTRUNAC

COMPANY, S.A. DE C.V.

500-05-2017-32063

dated August 22, 2017

September 18, 2017

October 16,

2017

CPD151208GBA

CONTRACTS AND

PROJECTS 2017,

S.A. DE C.V.

500-04-00-00-00-

2017-44661 dated

December 22,

2017

January 11, 2018

January 12, 2018

DAA151028GQ9

ASIA DISTRIBUTOR IN

AMERICA, S.A. DE

C.V.

500-72-05-01-02-

2019-2029 dated

July 08, 2019

July 12, 2019

July 29, 2019

GII1402249X7

IMPERIO IQ GROUP

THE HUMAN FACTOR,

S.C.

500-55-00-03-00-

2023-3239 dated

March 10, 2023

March 16, 2023

March 17, 2023

OFF1305168F1

OFFICECO, S.A. DE

C.V.

500-49-00-03-01-

2018-006144 dated

September 25,

2018

October 08,

2018

October 09,

2018

PAD1204167F4

SUPPLY, ADMINISTER

AND DISTRIBUTE

SERVICES, S.A. DE

C.V.

500-04-00-00-00-

2021-27048 dated

September 06,

2021

September 10,

2021

September 13,

2021

PEGL760303T50

PEREZ COVARRUBIAS

GARCIA LUIS

FERNANDO

500-29-00-04-01-

2016-12848 dated

December 07,

2016

December 08, 2016

January 16,

2017

VITF8009028T1

VILLARUEL TORRES

FRANCIA IDALIA

500-70-00-07-02-

2017-03270 dated

March 21, 2017

April 03, 2017

April 28, 2017

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Fiscal Address

Predominant Activity

Reason for the Procedure

BRI131216PG6

BRIJ, S.C. DE S. DE R.L. DE C.V.

Cuauhtémoc Borough, Mexico City

Accounting and audit services

Absence of assets

Absence of

personnel

Lack of infrastructure

CAR160229F29

CARYRA, S. DE R.L. DE C.V.

Tijuana, Baja California

Management consulting services

Absence of assets

Absence of

personnel

CGI150128J25

COMERCIALIZADORA GIBRANTE,

S.A. DE C.V.

Guadalajara, Jalisco

Training and advice on personnel management

Absence of assets

Absence of

personnel

CKU120906LY6

COMERCIALIZADORA KUMMILTO,

S.A. DE C.V.

Cuernavaca, Morelos

Other business support services

Absence of assets

Absence of

personnel

Lack of infrastructure

CON0812224Q1

CONSTRUNAC COMPANY, S.A. DE

C.V.

Benito Juárez Borough, Mexico City

Wholesale trade of fresh fruits and vegetables

Absence of assets

Absence of

personnel

CPD151208GBA

CONTRACTS AND PROJECTS 2017,

S.A. DE C.V.

Culiacán, Sinaloa

Wholesale trade of other construction materials, except wood

Absence of assets

Absence of

personnel

DAA151028GQ9

ASIA DISTRIBUTOR IN AMERICA,

S.A. DE C.V.

Cuauhtémoc Borough, Mexico City

Other wholesale trade intermediaries

Absence of assets

Absence of

personnel

GII1402249X7

IMPERIO IQ GROUP THE HUMAN

FACTOR, S.C.

Cuauhtémoc Borough, Mexico City

Other professional, scientific and

technical services

Absence of assets

Absence of

personnel

Lack of infrastructure

OFF1305168F1

OFFICECO, S.A. DE C.V.

Benito Juárez, Quintana Roo

Management consulting services

Absence of assets

Lack of

infrastructure

No material capacity

PAD1204167F4

SUPPLY, ADMINISTER AND

DISTRIBUTE SERVICES, S.A. DE

C.V.

Hermosillo, Sonora.

Administration and supervision of

Construction of commercial, institutional and service buildings

Absence of assets

Absence of

personnel

No material capacity

PEGL760303T50

PEREZ COVARRUBIAS GARCIA

LUIS FERNANDO

Mineral de la Reforma, Hidalgo

Electrical installations in constructions

Absence of assets

Absence of

personnel

Lack of infrastructure

No material capacity

VITF8009028T1

VILLARUEL TORRES FRANCIA

IDALIA

Zacatecas, Zacatecas

Sale of minerals with gold, silver and lead values

Absence of assets

Absence of

personnel

Lack of infrastructure

For the above reason, the name or corporate 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, denomination or corporate name of the

Taxpayer

Number and date of office containing in Global List

Definitive

Date of publication in the

Official Gazette of the Federation

BRI131216PG6

BRIJ, S.C. DE S. DE R.L. DE C.V.

500-05-2018-29849 dated October 26, 2018

November 21, 2018

CAR160229F29

CARYRA, S. DE R.L. DE C.V.

500-05-2018-10859 dated April 27, 2018

May 21, 2018

CGI150128J25

COMERCIALIZADORA GIBRANTE, S.A. DE C.V.

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

August 21, 2018

CKU120906LY6

COMERCIALIZADORA KUMMILTO, S.A. DE C.V.

500-05-2018-32782 dated December 12, 2018

January 14, 2019

CON0812224Q1

CONSTRUNAC COMPANY, S.A. DE C.V.

500-05-2017-38830 dated December 22, 2017

January 29, 2018

CPD151208GBA

CONTRACTS AND PROJECTS 2017, S.A. DE C.V.

500-05-2018-8116 dated February 27, 2018

March 13, 2018

DAA151028GQ9

ASIA DISTRIBUTOR IN AMERICA, S.A. DE C.V.

500-05-2019-27926 dated September 25, 2019

October 17, 2019

GII1402249X7

IMPERIO IQ GROUP THE HUMAN FACTOR, S.C.

500-05-2018-22861 dated August 27, 2018

October 08, 2018

OFF1305168F1

OFFICECO, S.A. DE C.V.

500-05-2019-5125 dated January 21, 2019

February 19, 2019

PAD1204167F4

SUPPLY, ADMINISTER AND DISTRIBUTE SERVICES,

S.A. DE C.V.

500-05-2021-26245 dated November 25, 2021

December 15, 2021

PEGL760303T50

PEREZ COVARRUBIAS GARCIA LUIS FERNANDO

500-05-2017-16004 dated April 24, 2017

May 10, 2017

VITF8009028T1

VILLARUEL TORRES FRANCIA IDALIA

500-05-2017-32168 dated September 26, 2017

October 26, 2017

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

defense, which were concluded with the following resolution or sentence:

No.

R.F.C.

Name, denomination or

corporate 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

BRI131216PG6

BRIJ, S.C. DE S. DE R.L. DE

C.V.

Nullity Trial 25186/

18-17-07-8

November 07,

2019

Seventh Regional Metropolitan Chamber of the

Federal Tribunal of

Administrative Justice

The nullity of the challenged resolution 500-72-03-01-2018- 12602 of August 31, 2018, issued by the

Concentrated Administration of Fiscal Audit of Mexico City "2" is declared.

CAR160229F29

CARYRA, S. DE R.L. DE C.V.

Nullity Trial 3524/

22-01-01-9

August 13, 2024

First Regional Chamber of the Northwest I of the

Federal Tribunal of

Administrative Justice

The nullity of the challenged resolution 500-10-00-06-01-2018-07642 of

February 06, 2018, issued by the

Concentrated Administration of Fiscal Audit of Baja California "2" is declared.

CGI150128J25

COMERCIALIZADORA

GIBRANTE, S.A. DE C.V.

Nullity Trial 2782/

20-07-01-8

April 09, 2021

First Regional Chamber of the West of the

Federal Tribunal of

Administrative Justice

The nullity of the challenged resolution 500-31-00-04-01-2018-12154 of

February 08, 2018, issued by the

Concentrated Administration of Fiscal Audit of Jalisco "2" is declared.

CKU120906LY6

COMERCIALIZADORA

KUMMILTO, S.A. DE C.V.

Nullity Trial 19/

1106-24-01-03-03-OL

May 02, 2024

Specialized Mixed Chamber in Online Trials and in

Environmental and Regulatory Matters of the Federal Tribunal of

Administrative Justice

The nullity of the challenged resolution 500-70-00-05-03-2018-08619 of

August 02, 2018, issued by the

Concentrated Administration of Fiscal Audit of Zacatecas "1" is declared.

CON0812224Q1

CONSTRUNAC COMPANY,

S.A. DE C.V.

Nullity Trial 21051/

23-17-07-7

June 05, 2025

Seventh Regional Chamber in Mexico City of the

Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 600-74-00-02-00-2023- 10110 of July 13, 2023, issued by the

Concentrated Legal Administration of

Mexico City "4", which resolved the Online Administrative Revocation Appeal

RRL2021009293, as well as the

originally appealed 500-05-2017-32063 of

August 22, 2017, signed by the

Central Administration of Strategic Audit is declared.

CPD151208GBA

CONTRACTS AND PROJECTS

2017, S.A. DE C.V.

Nullity Trial 2906/

21-03-01-5

September 01, 2023

First Regional Chamber of the Northwest III of the

Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 500-04-00-00-00-2017- 44661 dated December 22, 2017, is declared,

issued by the Central Administration of

Verification and Evaluation of Federal Entities in

Fiscal Coordination Matters.

DAA151028GQ9

ASIA DISTRIBUTOR IN

AMERICA, S.A. DE C.V.

Nullity Trial 19/

1878-24-01-03-06-OL

November 30, 2021

Specialized Chamber in

Online Trials of the

Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 500-72-05-01-02-2019- 2029 of July 08, 2019, issued by the

Concentrated Administration of Fiscal Audit of Mexico City "2" is declared.

GII1402249X7

IMPERIO IQ GROUP THE

HUMAN FACTOR, S.C.

Nullity Trial 9980/

23-17-05-3

June 28, 2024

Fifth Regional Metropolitan Chamber of the

Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 500-55-00-03-00-2023- 3239 of March 10, 2023, issued by the

Concentrated Administration of Fiscal Audit of Sonora "2" is declared.

OFF1305168F1

OFFICECO, S.A. DE C.V.

Nullity Trial 1735/

20-12-02-2

March 02, 2023

Second Regional Chamber of the East of the Tribunal

of Administrative Justice

The absolute nullity of the challenged resolution 600-49-2020-00-987 of

June 02, 2020, issued by the

Concentrated Legal Administration of

Quintana Roo "2", which resolved the Online Administrative Revocation Appeal

RRL201811600, as well as the originally

appealed 500-49-00-03-01-2018-006144 of September 25

2018, issued by the

Concentrated Administration of Fiscal Audit of Quintana Roo "2" is declared.

PAD1204167F4

SUPPLY, ADMINISTER AND

DISTRIBUTE SERVICES, S.A.

DE C.V.

Nullity Trial 2109/

21-02-01-2

June 13, 2023

Regional Chamber of the Northwest II of the Tribunal

of Administrative Justice

The absolute nullity of the challenged resolution 500-04-00-00-00-2021- 27048 of September 06, 2021, issued

by the Central Administration of Verification and

Evaluation of Federal Entities in

Fiscal Coordination Matters is declared.

PEGL760303T50

PEREZ COVARRUBIAS

GARCIA LUIS FERNANDO

Nullity Trial 1849/

21-09-01-5-OT

November 05, 2024

Regional Chamber of the Center II of the Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 500-29-00-04-01-2016- 12848 of December 07, 2016, issued

by the Concentrated Administration of

Fiscal Audit of Hidalgo "1" is declared.

VITF8009028T1

VILLARUEL TORRES FRANCIA

IDALIA

Nullity Trial 145/

23-23-01-7

September 26, 2023

Regional Chamber of the North

Center IV and Auxiliary of the

Federal Tribunal of

Administrative Justice

The absolute nullity of the challenged resolution 500-70-00-07-02-2017- 03270 of March 21, 2017, issued by the

Concentrated Administration of Fiscal Audit of Zacatecas "1" is declared.

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 ineffective.

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

liability they may have regarding other fiscal receipts they 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.

Respectfully.

Mexico City, August 12, 2025. - Central Administrator of Strategic Audit, L.C.

Rubén Martín López Rodríguez. - Signature.

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