Regulatory Alerts2025-10-03 | DOF 5769103Added
Notice 500-05-2025-20450 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code
The Strategic Fiscal Audit Central Administration communicates that the tax procedures initiated against twelve specific taxpayers under Article 69-B of the Federal Tax Code (valid until July 24, 2018) have been rendered without effect. This outcome results from final judicial resolutions declaring the nullity of the original presumption notices or definitive resolutions for entities including BRIJ, S.C., CARYRA, S. de R.L. de C.V., and COMERCIALIZADORA GIBRANTE, S.A. de C.V. The document clarifies that obtaining this favorable resolution does not exempt these taxpayers from liability regarding other fiscal receipts issued without the necessary assets, personnel, infrastructure, or material capacity.
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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
01
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
02
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
03
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
04
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
05
CON0812224Q1
CONSTRUNAC
COMPANY, S.A. DE C.V.
500-05-2017-32063
dated August 22, 2017
September 18, 2017
October 16,
2017
06
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
07
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
08
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
09
OFF1305168F1
OFFICECO, S.A. DE
C.V.
500-49-00-03-01-
2018-006144 dated
September 25,
2018
October 08,
2018
October 09,
2018
10
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
11
PEGL760303T50
PEREZ COVARRUBIAS
GARCIA LUIS
FERNANDO
500-29-00-04-01-
2016-12848 dated
December 07,
2016
December 08, 2016
January 16,
2017
12
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
01
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
02
CAR160229F29
CARYRA, S. DE R.L. DE C.V.
Tijuana, Baja California
Management consulting services
Absence of assets
Absence of
personnel
03
CGI150128J25
COMERCIALIZADORA GIBRANTE,
S.A. DE C.V.
Guadalajara, Jalisco
Training and advice on personnel management
Absence of assets
Absence of
personnel
04
CKU120906LY6
COMERCIALIZADORA KUMMILTO,
S.A. DE C.V.
Cuernavaca, Morelos
Other business support services
Absence of assets
Absence of
personnel
Lack of infrastructure
05
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
06
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
07
DAA151028GQ9
ASIA DISTRIBUTOR IN AMERICA,
S.A. DE C.V.
Cuauhtémoc Borough, Mexico City
Other wholesale trade intermediaries
Absence of assets
Absence of
personnel
08
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
09
OFF1305168F1
OFFICECO, S.A. DE C.V.
Benito Juárez, Quintana Roo
Management consulting services
Absence of assets
Lack of
infrastructure
No material capacity
10
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
11
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
12
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
01
BRI131216PG6
BRIJ, S.C. DE S. DE R.L. DE C.V.
500-05-2018-29849 dated October 26, 2018
November 21, 2018
02
CAR160229F29
CARYRA, S. DE R.L. DE C.V.
500-05-2018-10859 dated April 27, 2018
May 21, 2018
03
CGI150128J25
COMERCIALIZADORA GIBRANTE, S.A. DE C.V.
500-05-2018-20842 dated July 12, 2018
August 21, 2018
04
CKU120906LY6
COMERCIALIZADORA KUMMILTO, S.A. DE C.V.
500-05-2018-32782 dated December 12, 2018
January 14, 2019
05
CON0812224Q1
CONSTRUNAC COMPANY, S.A. DE C.V.
500-05-2017-38830 dated December 22, 2017
January 29, 2018
06
CPD151208GBA
CONTRACTS AND PROJECTS 2017, S.A. DE C.V.
500-05-2018-8116 dated February 27, 2018
March 13, 2018
07
DAA151028GQ9
ASIA DISTRIBUTOR IN AMERICA, S.A. DE C.V.
500-05-2019-27926 dated September 25, 2019
October 17, 2019
08
GII1402249X7
IMPERIO IQ GROUP THE HUMAN FACTOR, S.C.
500-05-2018-22861 dated August 27, 2018
October 08, 2018
09
OFF1305168F1
OFFICECO, S.A. DE C.V.
500-05-2019-5125 dated January 21, 2019
February 19, 2019
10
PAD1204167F4
SUPPLY, ADMINISTER AND DISTRIBUTE SERVICES,
S.A. DE C.V.
500-05-2021-26245 dated November 25, 2021
December 15, 2021
11
PEGL760303T50
PEREZ COVARRUBIAS GARCIA LUIS FERNANDO
500-05-2017-16004 dated April 24, 2017
May 10, 2017
12
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
01
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.
02
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.
03
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.
04
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.
05
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.
06
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.
07
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.
08
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.
09
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.
10
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.
11
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.
12
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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