Regulatory Alerts2025-10-10 | DOF 5769720Added
Notice 500-05-2025-31296 communicating the definitive global list under Article 69-B, fourth paragraph of the Federal Tax Code
The Strategic Tax Audit Administration publishes the definitive global list of six taxpayers who failed to rebut the presumption that they issued fiscal receipts without assets, personnel, infrastructure, or material capacity. The listed entities are Construcciones y Cimentaciones Catover, S.A. de C.V., Comercializadora Covzar, S.A. de C.V., Construcciones Zaide, S.A. de C.V., Grupo MRI Cancun, S. de R.L. de C.V., Ingersa Construcciones, S.A. de C.V., and Servicios y Asesoria Manlla, S.A. de C.V. Consequently, fiscal receipts issued by these taxpayers are declared to have produced no fiscal effect. The publication occurs after the mandatory thirty-business-day period following the notification of definitive resolutions had expired without successful legal challenges.
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DOF: 10/10/2025
OFFICE 500-05-2025-31296 through which the definitive global list is communicated 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 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: 500-05-2025-31296
Subject:
The definitive global list is communicated 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 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 Service of Tax Administration, 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, first paragraph, 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 force from November 22, 2015, in conformity with what is provided 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, in force from January 01, 2022, in conformity with what is provided in the First Transitory Article of said Decree; Article Third, 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, in force from July 23, 2016, in conformity with what is provided in the First Transitory Article of said Agreement; as well as in Articles 33, last paragraph, 63, and 69-B first, fourth and fifth paragraphs of the Federal Tax Code of the Federation, notifies the following:
As a result of the exercise of the attributions and powers 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 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 that cover 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 with numeral 69 of the Regulations of said Code, issued an individual presumption office to each one of the taxpayers mentioned in the cited Annex 1, and in said office the reasons and grounds were indicated by 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 conformity 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 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, to make the statements and provide the evidence they considered pertinent to disprove the facts given notice through the cited offices, warned that if after the granted term they did not provide documentation and information and/or what they exhibited, once valued, did not disprove the facts indicated in the offices of merit, 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 to publish their names, denominations or trade names in the list of taxpayers who did not disprove the facts given notice and therefore, would be in definitive form in the situation referred to in 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 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 notice 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 imputed 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 of the taxpayers indicated in Annex 1, section D, of this present office.
For the above 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 subsequent to the notification of the resolution and that, at the date said term has passed since the notification of the resolution and, in addition 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 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 the 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 imputed to them and therefore, 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, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the above, since it is of public interest that the billing of non-existent operations be stopped, as well as that society knows who those are taxpayers who carry out this type of operations.
Respectfully.
Mexico City, September 02, 2025. - Central Administrator of Strategic Audit, L.C. Rubén Martín López Rodríguez .- Rubric.
Annex 1 of office number 500-05-2025-31296 dated September 02, 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 of the Federation
Section A.- Notification of the PRESUMPTION OFFICE in accordance with the first and second paragraphs 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 presumption office
Issuing Authority of the individual presumption office
Means of notification to the taxpayer
Authority's public notice
Personal notification
Notification via Tax Box
Date of fixing in the public notice 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
1 CCC120102SC7 CONSTRUCCIONES Y CIMENTACIONES CATOVER, S.A. DE C.V. 500-05-2025-5628 dated January 13 2025 Central Administration of Strategic Audit January 14, 2025 January 15 2025
2 CCO120102MP2 COMERCIALIZADORA COVZAR, S.A. DE C.V. 500-05-2025-5626 dated January 13 2025 Central Administration of Strategic Audit January 14, 2025 January 15 2025
3 CZA130212QM5 CONSTRUCCIONES ZAIDE, S.A. DE C.V. 500-05-2025-5624 dated January 13 2025 Central Administration of Strategic Audit January 14, 2025 January 15 2025
4 GRC161101223 GRUPO MRI CANCUN, S. DE R.L. DE C.V. 500-49-00-03-01- 2024-010140 dated November 21 2024 Decentralized Administration of Fiscal Audit of Quintana Roo "2" November 27, 2024 November 28, 2024
5 ICO181012ER6 INGERSA CONSTRUCCIONES, S.A. DE C.V. 500-05-2024-25901 dated November 29 2024 Central Administration of Strategic Audit December 05 2024 December 06 2024
6 SAM150421F58 SERVICIOS Y ASESORIA MANLLA, S.A. DE C.V. 500-18-00-05-02- 2020-6939 dated November 23, 2020 Central Administration of Strategic Audit November 25, 2020 November 26, 2020
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 office
Issuing Authority of the global presumption office
Date of notification on the internet page of the Service of Tax Administration
Date on which the notification took effect
1 CCC120102SC7 CONSTRUCCIONES Y CIMENTACIONES CATOVER, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit February 12, 2025 February 13, 2025
2 CCO120102MP2 COMERCIALIZADORA COVZAR, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit February 12, 2025 February 13, 2025
3 CZA130212QM5 CONSTRUCCIONES ZAIDE, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit February 12, 2025 February 13, 2025
4 GRC161101223 GRUPO MRI CANCUN, S. DE R.L. DE C.V. 500-05-2024-26177 dated December 13 2024 Central Administration of Strategic Audit December 13, 2024 December 16, 2024
5 ICO181012ER6 INGERSA CONSTRUCCIONES, S.A. DE C.V. 500-05-2024-26177 dated December 13 2024 Central Administration of Strategic Audit December 13, 2024 December 16, 2024
6 SAM150421F58 SERVICIOS Y ASESORIA MANLLA, S.A. DE C.V. 500-05-2021-5117 dated February 18 2021 Central Administration of Strategic Audit February 18, 2021 February 19, 2021
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 office
Issuing Authority of the global presumption office
Date of notification in the Official Gazette of the Federation
Date on which the notification took effect
1 CCC120102SC7 CONSTRUCCIONES Y CIMENTACIONES CATOVER, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit April 04, 2025 April 07, 2025
2 CCO120102MP2 COMERCIALIZADORA COVZAR, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit April 04, 2025 April 07, 2025
3 CZA130212QM5 CONSTRUCCIONES ZAIDE, S.A. DE C.V. 500-05-2025-5882 dated February 12 2025 Central Administration of Strategic Audit April 04, 2025 April 07, 2025
4 GRC161101223 GRUPO MRI CANCUN, S. DE R.L. DE C.V. 500-05-2024-26177 dated December 13 2024 Central Administration of Strategic Audit January 24, 2025 January 27, 2025
5 ICO181012ER6 INGERSA CONSTRUCCIONES, S.A. DE C.V. 500-05-2024-26177 dated December 13 2024 Central Administration of Strategic Audit January 24, 2025 January 27, 2025
6 SAM150421F58 SERVICIOS Y ASESORIA MANLLA, S.A. DE C.V. 500-05-2021-5117 dated February 18 2021 Central Administration of Strategic Audit March 09, 2021 March 10, 2021
Section D.- Notification of the definitive RESOLUTION office 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
Means of notification to the taxpayer
Authority's public notice
Personal notification
Notification via Tax Box
Date of fixing in the public notice 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
1 CCC120102SC7 CONSTRUCCIONES Y CIMENTACIONES CATOVER, S.A. DE C.V. 500-05-2025-24224 dated July 03 2025 Central Administration of Strategic Audit July 04, 2025 July 07, 2025
2 CCO120102MP2 COMERCIALIZADORA COVZAR, S.A. DE C.V. 500-05-2025-24225 dated July 03 2025 Central Administration of Strategic Audit July 04, 2025 July 07, 2025
3 CZA130212QM5 CONSTRUCCIONES ZAIDE, S.A. DE C.V. 500-05-2025-24270 dated July 03 2025 Central Administration of Strategic Audit July 04, 2025 July 07, 2025
4 GRC161101223 GRUPO MRI CANCUN, S. DE R.L. DE C.V. 500-49-00-03-01- 2025-004479 dated April 25 2025 Central Administration of Strategic Audit May 02, 2025 May 06, 2025
5 ICO181012ER6 INGERSA CONSTRUCCIONES, S.A. DE C.V. 500-05-2025-11130 dated April 16 2025 Central Administration of Strategic Audit April 24, 2025 April 25, 2025
6 SAM150421F58 SERVICIOS Y ASESORIA MANLLA, S.A. DE C.V. // In compliance with the sentence issued in the Nullity Trial No. 044- 2021-02-C-15-04-02-01-L 500-18-00-05-02- 2025-3277 dated July 03, 2025 Central Administration of Strategic Audit July 03, 2025 July 04, 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 CCC120102SC7 CONSTRUCCIONES Y CIMENTACIONES CATOVER, S.A. DE C.V. CUAUHTÉMOC, MEXICO CITY
OTHER CIVIL ENGINEERING CONSTRUCTIONS OR HEAVY WORK
ABSENCE OF ASSETS, ABSENCE OF PERSONNEL, NO MATERIAL CAPACITY
2 CCO120102MP2 COMERCIALIZADORA COVZAR, S.A. DE C.V. HUIXQUILUCAN DE DEGOLLADO, STATE OF MEXICO
OTHER WHOLESALE COMMERCE INTERMEDIARIES
ABSENCE OF ASSETS, ABSENCE OF PERSONNEL, NO MATERIAL CAPACITY
3 CZA130212QM5 CONSTRUCCIONES ZAIDE, S.A. DE C.V. CUAUHTÉMOC, MEXICO CITY
MANAGEMENT AND SUPERVISION OF HOUSE CONSTRUCTION
ABSENCE OF ASSETS, ABSENCE OF PERSONNEL, NO MATERIAL CAPACITY
4 GRC161101223 GRUPO MRI CANCUN, S. OF R.L. DE C.V. BENITO JUÁREZ, QUINTANA ROO
CONSULTING SERVICES IN MANAGEMENT, ACCOUNTING AND AUDIT SERVICES, LAW FIRMS
ABSENCE OF ASSETS, ABSENCE OF PERSONNEL, LACK OF INFRASTRUCTURE, NO MATERIAL CAPACITY
5 ICO181012ER6 INGERSA CONSTRUCCIONES, S.A. DE C.V. COATZACOALCOS, VERACRUZ DE IGNACIO DE LA LLAVE
OTHER CIVIL ENGINEERING CONSTRUCTIONS OR HEAVY WORK
ABSENCE OF ASSETS, ABSENCE OF PERSONNEL, NO MATERIAL CAPACITY
6 SAM150421F58 SERVICIOS Y ASESORIA MANLLA, S.A. DE C.V. XALAPA, VERACRUZ OF IGNACIO DE LA LLAVE
ACCOUNTING AND AUDIT SERVICES
ABSENCE OF PERSONNEL, LACK OF INFRASTRUCTURE, NO MATERIAL CAPACITY
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