Regulatory Alerts2026-02-20 | DOF 5780610Added · Updated
Notice 500-05-2025-39144 Communicating the Definitive Global List under Article 69-B, Paragraph 4 of the Federal Tax Code
The Strategic Fiscal Audit Administration of the Tax Administration Service adds six taxpayers to the definitive global list of entities that failed to rebut the presumption of issuing fiscal receipts without assets, personnel, infrastructure, or material capacity. This action follows the expiration of the 15-business-day period for taxpayers to provide evidence and the subsequent issuance of definitive resolutions confirming their failure to disprove the imputed facts. Consequently, fiscal receipts issued by these entities are declared to have no fiscal effect for general purposes, and their names are published on the SAT website and in the Official Gazette.
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DOF: 20/02/2026
OFFICE 500-05-2025-39144 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 says: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.-
Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Fiscalization.
OFFICE: 500-05-2025-39144
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 Fiscalization, attached to the General Administration of Federal Fiscal Audit of the Tax Administration Service, based on what is established 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 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 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 force from November 22, 2015, in accordance with what is established 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 Customs Agency of Mexico are issued, published in the same official organ on December 21, 2021, in force from January 01, 2022, in accordance with what is established 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 accordance with what is established 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, 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 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 above in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax Code in force, in relation to Article 135 of the Federal Tax Code.
Attending what is established by 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 that which 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 passed, 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 for 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 evidence provided by those taxpayers, the aforementioned authorities considered that those taxpayers did not rebut the facts that were 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 above and, taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code, states that under no circumstances will the list be published before the thirty business days following the notification of the resolution and that, to 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, that has been initiated against them; therefore, in order to fully comply with the Third Resolutive contained in the aforementioned definitive resolutions, this Central Administration of Strategic Fiscalization, 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 that were 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, 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, in order to consider, with general effects, that the fiscal receipts issued by said taxpayers do not produce nor did they produce any fiscal effect, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the above, since it is in the public interest to stop the billing of non-existent operations, as well as for society to know who are those taxpayers who carry out this type of operations.
Respectfully.
Mexico City, November 25, 2025.- Central Administrator of Strategic Fiscalization, L.C. Rubén Martín López Rodríguez.- Rubric.
Annex 1 of office number 500-05-2025-39144 dated November 25, 2025, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT rebut the reason for which the presumption notice 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 the PRESUMPTION OFFICE 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 means to the taxpayer |
|---|---|---|---|---|
| Authority's Bench | ||||
| Date of fixing on the Authority's Bench | ||||
| 1 | ACA1612062H6 | ARMATOS, CONSTRUCTION, ADMINISTRATION AND SERVICES, S.A. DE C.V. | 500-50-00-05-01-2025-2287 dated May 09, 2025 | Disaggregated Administration of Fiscal Audit of San Luis Potosí "1" |
| 2 | CCI1611093E9 | C&C COMERCIALIZADORA INTEGRAL DE CHIAPAS, S.A. DE C.V. | 500-36-07-01-03-2024-17733 dated December 13, 2024 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 3 | END100707H8A | ENDRIAGO, S.A. DE C.V. | 500-36-07-01-03-2025-2831 dated February 28, 2025 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 4 | MGO210707EE5 | MAH - ONY, S.A. DE C.V. | 500-72-04-01-01-2025-20382 dated May 15, 2025 | Disaggregated Administration of Fiscal Audit of Federal District "2" |
| 5 | OIL131129VC7 | OPERADORA ISLA DE LA PASION, S.A. DE C.V. | 500-36-07-01-03-2025-3906 dated March 20, 2025 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 6 | SRM130624Q4A | STAFFING RESOURCING MÉXICO, S.A. DE C.V. | 500-18-00-07-01-2025-1145 dated May 15, 2025 | Disaggregated Administration of Fiscal Audit of Colima "1" |
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 | ACA1612062H6 | ARMATOS, CONSTRUCTION, ADMINISTRATION AND SERVICES, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 17 June 2025 |
| 2 | CCI1611093E9 | C&C COMERCIALIZADORA INTEGRAL DE CHIAPAS, S.A. DE C.V. | 500-05-2025-5882 dated February 12, 2025 | Central Administration of Strategic Fiscalization | 12 February 2025 |
| 3 | END100707H8A | ENDRIAGO, S.A. DE C.V. | 500-05-2025-10972 dated April 01, 2025 | Central Administration of Strategic Fiscalization | 01 April 2025 |
| 4 | MGO210707EE5 | MAH - ONY, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 17 June 2025 |
| 5 | OIL131129VC7 | OPERADORA ISLA DE LA PASION, S.A. DE C.V. | 500-05-2025-10972 dated April 01, 2025 | Central Administration of Strategic Fiscalization | 01 April 2025 |
| 6 | SRM130624Q4A | STAFFING RESOURCING MÉXICO, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 17 June 2025 |
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 | ACA1612062H6 | ARMATOS, CONSTRUCTION, ADMINISTRATION AND SERVICES, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 01 August 2025 |
| 2 | CCI1611093E9 | C&C COMERCIALIZADORA INTEGRAL DE CHIAPAS, S.A. DE C.V. | 500-05-2025-5882 dated February 12, 2025 | Central Administration of Strategic Fiscalization | 04 April 2025 |
| 3 | END100707H8A | ENDRIAGO, S.A. DE C.V. | 500-05-2025-10972 dated April 01, 2025 | Central Administration of Strategic Fiscalization | 25 April 2025 |
| 4 | MGO210707EE5 | MAH - ONY, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 01 August 2025 |
| 5 | OIL131129VC7 | OPERADORA ISLA DE LA PASION, S.A. DE C.V. | 500-05-2025-10972 dated April 01, 2025 | Central Administration of Strategic Fiscalization | 25 April 2025 |
| 6 | SRM130624Q4A | STAFFING RESOURCING MÉXICO, S.A. DE C.V. | 500-05-2025-20012 dated June 17, 2025 | Central Administration of Strategic Fiscalization | 01 August 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 means to the taxpayer |
|---|---|---|---|---|
| Authority's Bench | ||||
| Date of fixing on the Authority's Bench | ||||
| 1 | ACA1612062H6 | ARMATOS, CONSTRUCTION, ADMINISTRATION AND SERVICES, S.A. DE C.V. | 500-50-00-05-01-2025-3701 dated September 17, 2025 | Disaggregated Administration of Fiscal Audit of San Luis Potosí "1" |
| 2 | CCI1611093E9 | C&C COMERCIALIZADORA INTEGRAL DE CHIAPAS, S.A. DE C.V. | 500-36-07-01-03-2025-8699 dated July 08, 2025 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 3 | END100707H8A | ENDRIAGO, S.A. DE C.V. | 500-36-07-01-03-2025-9172 dated August 06, 2025 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 4 | MGO210707EE5 | MAH - ONY, S.A. DE C.V. | 500-72-04-01-01-2025-20511 dated September 10, 2025 | Disaggregated Administration of Fiscal Audit of Federal District "2" |
| 5 | OIL131129VC7 | OPERADORA ISLA DE LA PASION, S.A. DE C.V. | 500-36-07-01-03-2025-9150 dated August 04, 2025 | Disaggregated Administration of Fiscal Audit of Mexico "2" |
| 6 | SRM130624Q4A | STAFFING RESOURCING MÉXICO, S.A. DE C.V. | 500-18-00-07-01-2025-1372 dated September 29, 2025 | Disaggregated Administration of Fiscal Audit of Colima "1" |
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 | ACA1612062H6 | ARMATOS, CONSTRUCTION, ADMINISTRATION AND SERVICES, S.A. DE C.V. | SAN LUIS POTOSÍ, SAN LUIS POTOSÍ | OTHER CIVIL ENGINEERING CONSTRUCTIONS OR HEAVY WORK |
| 2 | CCI1611093E9 | C&C COMERCIALIZADORA INTEGRAL DE CHIAPAS, S.A. DE C.V. | TLALNEPANTLA DE BAZ, ESTADO MÉXICO | OTHER WHOLESALE TRADE INTERMEDIARIES |
| 3 | END100707H8A | ENDRIAGO, S.A. DE C.V. | ÁLVARO OBREGÓN, CIUDAD DE MÉXICO | ADVERTISING AGENCIES |
| 4 | MGO210707EE5 | MAH - ONY, S.A. DE C.V. | CUAUHTÉMOC, CIUDAD DE MÉXICO | OTHER BUSINESS SUPPORT SERVICES |
| 5 | OIL131129VC7 | OPERADORA ISLA DE LA PASION, S.A. DE C.V. | NAUCALPAN DE JUÁREZ, ESTADO DE MÉXICO | EXPORT SERVICES OF CONVENTIONS AND EXHIBITION SERVICES |
| 6 | SRM130624Q4A | STAFFING RESOURCING MÉXICO, S.A. DE C.V. | ZAPOPAN, JALISCO | BUSINESS ADMINISTRATION SERVICES |
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