Regulatory Alerts2026-04-30 | DOF 5786348Added · Updated
Notice 500-05-2025-39146 Communicating List of Taxpayers Who Challenged Presumption Notices or Resolutions Under Article 69-B of the Federal Tax Code and Had Them Declared Void
The Strategic Tax Audit Central Administration communicates that the tax procedures under Article 69-B of the Federal Tax Code against nine specific taxpayers have been rendered void following favorable judicial or administrative rulings. The document lists the taxpayers, their tax registration numbers, the specific legal challenges filed, and the resulting nullification of the original presumption or resolution notices. It further clarifies that this outcome does not exempt the taxpayers from liability regarding other fiscal documents issued without the necessary assets, personnel, infrastructure, or material capacity, preserving the tax authority's powers.
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DOF: 30/04/2026
OFFICE 500-05-2025-39146 through which a 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 or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act without effect.
A seal with the National Coat of Arms is placed at the margin, 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: 500-05-2025-39146
Subject:
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 (CFF) or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act without effect.
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 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 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 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 Agency of Customs 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; in Articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Federal Tax Code, communicates the following:
That to the taxpayers listed below, at some point, a Presumption Notice of non-existence of operations backed by certain fiscal receipts they issued was notified, this 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.
Following the procedure provided for in the aforementioned Article 69-B of the Federal Tax Code, and in terms of the fourth paragraph of the aforementioned article, the taxpayers in reference were notified of the definitive resolution as indicated below:
Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.
No.
Tax ID (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 board
Personal Notification
Tax Box
Date of posting on the Authority's public notice board
Date on which notification took effect
Date of notification
Date on which notification took effect
Date of notification
Date on which notification took effect
01
ACJ160118CG9
ARTE CALIDAD JALISCO, S.A. DE C.V.
500-30-00-06-00- 2019-00805 of April 16 2019
23 April 2019
24 April 2019
02
CEF140829R23
CONSULTORIA ESPECIALIZADA FAFC, S.A. DE C.V.
500-05-2020-23557 of October 06 2020
October 12 2020
October 13, 2020
03
DAS150305LZ6
DECISIONES ASERTIVAS, S.A. DE C.V.
500-05-2023-26379 of December 15 2023
January 08, 2024
January 09, 2024
04
ESR1508186K1
ESQUEMAS DE SOLUCION RAPIDA, S.A. DE C.V.
500-71-06-0103- 2021-31934 of May 27 2021
June 01, 2021
June 11, 2021
05
JIFD861206RS4
JIMENEZ FLORES DIEGO ALBERTO
500-64-00-06-02- 2020-006956 of May 11 2020
May 15, 2020
May 18, 2020
06
OST101214IL6
OPERADORA DE SERVICIOS TURISTICOS Y ECOLOGICOS BALUM CANAN, S.A. DE C.V.
500-65-00-04-03- 2020-17375 of December 15 2020
January 11, 2021
January 12, 2021
07
RCS161214MI3
REDEKA CORPORATIVO DE SOLUCIONES INTEGRALES, A.C.
500-30-00-07- 022019-00195 of January 10 2019
January 14, 2019
February 07, 2019
08
SOSS821113470
SORIANO SALINAS SELENE
500-36-05-01-01- 2022-11335 of September 22 2022
September 23, 2022
September 26, 2022
09
YED170614EE9
YERAY EDIFICACIONES, S.A. DE C.V.
500-42-00-08-00- 2021-0748 of January 28 2021
January 29, 2021
February 02, 2021
Additional data of the taxpayers.
No.
Tax ID (R.F.C.)
Name, denomination or corporate name of the Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
01
ACJ160118CG9
ARTE CALIDAD JALISCO, S.A. DE C.V.
Zapopan, Jalisco
Other specialized construction work
Absence of Assets Absence of Personnel
02
CEF140829R23
CONSULTORIA ESPECIALIZADA FAFC, S.A. DE C.V.
Benito Juárez, Mexico City
Consulting services in administration
Absence of Assets Absence of Personnel
03
DAS150305LZ6
DECISIONES ASERTIVAS, S.A. DE C.V.
Álvaro Obregón Borough, Mexico City
Other scientific and technical consulting services
Absence of Assets Absence of Personnel
No Material Capacity
04
ESR1508186K1
ESQUEMAS DE SOLUCION RAPIDA, S.A. DE C.V.
San Luis Potosí, San Luis Potosí
Consulting services in administration
Absence of Assets Absence of Personnel
05
JIFD861206RS4
JIMENEZ FLORES DIEGO ALBERTO
Cuauhtémoc Borough, Mexico City
Other wholesale trade intermediaries
Absence of Assets Absence of Personnel
Lack of Infrastructure No Material Capacity
06
OST101214IL6
OPERADORA DE SERVICIOS TURISTICOS Y ECOLOGICOS BALUM CANAN, S.A. DE C.V.
Boca del Río, Veracruz
Consulting services in administration
Absence of Assets Absence of Personnel
Lack of Infrastructure No Material Capacity
07
RCS161214MI3
REDEKA CORPORATIVO DE SOLUCIONES INTEGRALES, A.C.
Guadalajara, Jalisco
Associations and employer organizations
Absence of Assets Absence of Personnel
08
SOSS821113470
SORIANO SALINAS SELENE
Ecatepec de Morelos, State of Mexico
Manufacture of wire, wire products and springs
Absence of Assets Absence of Personnel
09
YED170614EE9
YERAY EDIFICACIONES, S.A. DE C.V.
General Escobedo, Nuevo León
Other civil engineering constructions or heavy work
Absence of Assets Lack of Infrastructure
No Material Capacity
For the above reason, the name or corporate name of the taxpayers who were notified of the aforementioned resolutions, were added to the list referred to in the fourth paragraph of Article 69-B of the Federal Tax Code, which was published in the Official Gazette of the Federation, as indicated below:
No.
Tax ID (R.F.C.)
Name, denomination or corporate name of the Taxpayer
Number and date of office containing in Global Definitive List
Date of publication in the Official Gazette of the Federation
01
ACJ160118CG9
ARTE CALIDAD JALISCO, S.A. DE C.V.
This taxpayer was not published in the definitive global lists.
02
CEF140829R23
CONSULTORIA ESPECIALIZADA FAFC, S.A. DE C.V.
500-05-2021-5303 dated March 04, 2021
March 18, 2021
03
DAS150305LZ6
DECISIONES ASERTIVAS, S.A. DE C.V.
500-05-2024-6681 dated February 29, 2024
May 31, 2024
04
ESR1508186K1
ESQUEMAS DE SOLUCION RAPIDA, S.A. DE C.V.
500-05-2021-25950 dated August 25, 2021
September 21, 2021
05
JIFD861206RS4
JIMENEZ FLORES DIEGO ALBERTO
500-05-2020-13754 dated July 10, 2020
August 06, 2020
06
OST101214IL6
OPERADORA DE SERVICIOS TURISTICOS Y ECOLOGICOS BALUM CANAN, S.A. DE C.V.
500-05-2021-5303 dated March 04, 2021
March 18, 2021
07
RCS161214MI3
REDEKA CORPORATIVO DE SOLUCIONES INTEGRALES, A.C.
500-05-2019-27685 dated August 14, 2019
September 05, 2019
08
SOSS821113470
SORIANO SALINAS SELENE
This taxpayer was not published in the definitive global lists.
09
YED170614EE9
YERAY EDIFICACIONES, S.A. DE C.V.
500-05-2021-10941 dated April 15, 2021
April 30, 2021
Disagreeing with the individual presumption office or definitive resolution office, they filed means of defense, which were concluded with the following resolutions or sentences:
No.
Tax ID (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 final resolution or sentence
01
ACJ160118CG9
ARTE CALIDAD JALISCO, S.A. DE C.V.
Revocation Appeal RRL2019004582
October 28, 2019
Concentrated Legal Administration of Jalisco "1"
The appealed resolution 500-30-00-06- 00-2019-00805 of April 16, 2019, issued by the Concentrated Administration of Fiscal Audit of Jalisco "1" is left without effect.
02
CEF140829R23
CONSULTORIA ESPECIALIZADA FAFC, S.A. DE C.V.
Nullity Trial 1677/ 22-27-01-1
September 01, 2025
Regional Chamber in Hidalgo of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 600-57-00-06-00-2022-5738 of July 12, 2022, issued by the Concentrated Legal Administration of the Federal District "2", which resolved the Online Administrative Revocation Appeal RRL2020010320, as well as, of the originally appealed 500-05-2022- 23557 dated October 06, 2020, signed by the Central Administration of Strategic Audit is declared.
03
DAS150305LZ6
DECISIONES ASERTIVAS, S.A. DE C.V.
Nullity Trial 3769/ 25-17-02-3
May 30, 2025
Second Metropolitan Regional Chamber of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 600-74-00-02-00-2024-19045 of December 18, 2024, issued by the Concentrated Legal Administration of the Federal District "4", which resolved the Online Administrative Revocation Appeal RRL2024002154, as well as, of the originally appealed 500-05-2023-26379 of December 15, 2023, signed by the Central Administration of Strategic Audit is declared.
04
ESR1508186K1
ESQUEMAS DE SOLUCION RAPIDA, S.A. DE C.V.
Nullity Trial 1791/ 21-25-01-2
August 02, 2024
Regional Chamber of San Luis Potosí of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 500- 71-06-01-03-2021-31934 of May 27, 2021, issued by the Concentrated Administration of Fiscal Audit of the Federal District "1" is declared.
05
JIFD861206RS4
JIMENEZ FLORES DIEGO ALBERTO
Nullity Trial 7826/ 20-17-10-7
February 04, 2025
Tenth Metropolitan Regional Chamber of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 500- 64-00-06-02-2020-006956 of May 11, 2020, issued by the Concentrated Administration of Fiscal Audit of Veracruz "1" is declared.
06
OST101214IL6
OPERADORA DE SERVICIOS TURISTICOS Y ECOLOGICOS BALUM CANAN, S.A. DE C.V.
Nullity Trial 1344/ 21-02-01-4
April 26, 2024
Regional Chamber of the Northwest II of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 600- 65-00-03-00-2021-1653 of May 21, 2021, issued by the Concentrated Legal Administration of Veracruz "2", which resolved the Online Administrative Revocation Appeal RRL2021001987, as well as, of the originally appealed 500-65-00-04-03-2020-17375 of December 15, 2020, signed by the Concentrated Administration of Fiscal Audit of Veracruz "2" is declared.
07
RCS161214MI3
REDEKA CORPORATIVO DE SOLUCIONES INTEGRALES, A.C.
Nullity Trial 7067/ 22-07-01-4
May 24, 2024
First Regional Chamber of Occident of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 500-30-00-07-02-2019-00195 of January 10, 2019, issued by the Concentrated Administration of Fiscal Audit of Jalisco "1" is declared.
08
SOSS821113470
SORIANO SALINAS SELENE
Nullity Trial 2949/ 22-11-02-3-OT
November 07, 2024
Second Regional Chamber North-East of the State of Mexico of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 500-36-05-01-01-2022-11335 of September 22, 2022, issued by the Concentrated Administration of Fiscal Audit of Mexico "2" is declared.
09
YED170614EE9
YERAY EDIFICACIONES, S.A. DE C.V.
Nullity Trial 6377/ 21-06-01-9-OT
May 17, 2023
First Regional Chamber of Northeast of the Federal Tribunal of Administrative Justice
The nullity of the challenged resolution 600- 42-2021-02-5871 of July 14, 2021, issued by the Concentrated Legal Administration of Nuevo León "2", which resolved the Online Administrative Revocation Appeal RRL2021003292, as well as, of the originally appealed 500-42-00-08-00-2021-0748 dated January 28, 2021, signed by the Concentrated Administration of Fiscal Audit of Nuevo León "2" is declared.
In view of the above, it is communicated that, as a consequence of the means of defense indicated in preceding paragraphs, the procedure of Article 69-B of the Federal Tax Code, followed against those taxpayers, has been left without effect.
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 the responsibility they may have regarding other fiscal receipts they have 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 reason, the powers of the tax authority are reserved.
Sincerely.
Mexico City, November 25, 2025.- Central Administrator of Strategic Audit, L.C. Rubén Martín López Rodríguez .- Rubric.
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