RegAlertRule · SHCP · 28 Feb 2025 · DOF 5750574
Notice 500-05-2025-5693 Communicating the Definitive Global List Under Article 69-B, Paragraph Four of the Federal Tax Code
The Strategic Audit Central Administration of the SAT publishes the definitive global list of taxpayers who failed to rebut the presumption that they issued fiscal receipts without assets, personnel, infrastructure, or material capacity. This list includes CAMPORTADOR, S.P.R. DE R.L. DE C.V., CONSTRUCCIONES EKT, S.A. DE C.V., and SUCCESS 21 ENTERPRISES, S.A. DE C.V., whose fiscal receipts are declared to produce no fiscal effect. The publication occurs after the mandatory thirty-business-day period following the notification of definitive resolutions and the expiration of the fifteen-business-day deadline for taxpayers to provide evidence.
DOF: 28/02/2025
OFFICE 500-05-2025-5693 communicating the definitive global list under Article 69-B, paragraph four 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: 500-05-2025-5693
Subject:
Communicating the definitive global list under Article 69-B, paragraph four 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 the provisions of 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, amended by Decree published in the same Official Gazette of the Federation on June 12, 2003; 1, 2, first paragraphs, 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, effective from November 22, 2015, in conformity with the provisions of the first paragraph of the First Transitory Article of said Regulations and amended by Decree amending and adding various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Tax Administration Service, 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, effective from January 01, 2022, in conformity with the provisions of 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, effective from July 23, 2016, in conformity with the provisions of 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 office to each of the taxpayers mentioned in the aforementioned Annex 1, and in said office, 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 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 by 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 conformity with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax Code in force, in relation to the
Article 135 of the Federal Tax Code.
Attending to the provisions of 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 rebut the facts made known through the aforementioned offices, warned that if after the granted term they did not provide the documentation and information and/or what they exhibited, once evaluated, did not rebut the facts indicated in the offices 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 to publish their names, denominations, or corporate 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 said Article 69-B of the Federal Tax Code.
Once the term indicated in the preceding paragraph has elapsed, 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, various information, documentation, and arguments in order to rebut the facts made known 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 aforementioned authorities considered that those taxpayers did not rebut 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 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 stated, and taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code states that in no case will the list be published before the thirty business days following the notification of the resolution and that, to date, said term 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, which has been initiated against them; therefore, in order to fully comply with Resolutive Third contained in the aforementioned 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 this, proceeds to add the names, denominations, or corporate names of the taxpayers indicated in Annex 1 of this office, to the list of taxpayers who did not rebut the facts imputed to them and therefore, are in a definitive 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 of them, a 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 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 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, January 27, 2025. - In substitution for the absence of the Central Administrator of Strategic Audit, from the Coordinator of Strategic Audit, from the Administrator of Strategic Audit " 1 ", " 2 ", " 3 ", " 4 ", " 5 " and " 6 ", based on Articles 4, fourth paragraph, and 22, last paragraph, numeral 5 subsection h), of the Internal Regulations of the Tax Administration Service in force, signs:
C.P. Nayeli Margarita Ramos Hernández , Administrator of Strategic Audit " 7 ".- Rubric.
Annex 1 of office number 500-05-2025-5693 dated January 27, 2025, corresponding to taxpayers who DID
provide arguments and/or proofs, but DID NOT rebut 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
Section A.- Notification of the PRESUMPTION OFFICE according to 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 corporate 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 files
Personal notification
Notification via Tax Box
Date of fixing in the
Authority's files
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
CAM120703914
CAMPORTADOR, S.P.R.
DE R.L. DE C.V.
500-05-2024-12804 dated June 19
2024
Central Administration of
Strategic Audit
June 25, 2024
June 26, 2024
2
CEK210703AHA
CONSTRUCCIONES
EKT, S.A. DE C.V.
500-05-2024-12805 dated June 19
2024
Central Administration of
Strategic Audit
June 25, 2024
June 26, 2024
3
SVE150305JK2
SUCCESS 21
ENTERPRISES,
S.A. DE
C.V.
500-74-05-03-01-
2024-3128 dated
May 13, 2024
Decentralized Administration of
Fiscal Audit of
Federal District "4"
May 17, 2024
May 20, 2024
Section B.- Notification on the Internet page of the Tax Administration Service.
R.F.C.
Name, denomination or corporate 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 Tax Administration Service
Date on which the notification took effect
1
CAM120703914
CAMPORTADOR, S.P.R. DE R.L.
DE C.V.
500-05-2024-13073 dated July 08
2024
Central Administration of
Strategic Audit
July 08, 2024
July 09, 2024
2
CEK210703AHA
CONSTRUCCIONES EKT,
S.A. DE
C.V.
500-05-2024-13073 dated July 08
2024
Central Administration of
Strategic Audit
July 08, 2024
July 09, 2024
3
SVE150305JK2
SUCCESS 21 ENTERPRISES, S.A.
DE C.V.
500-05-2024-12759 dated June 10
2024
Central Administration of
Strategic Audit
June 10, 2024
June 11, 2024
Section C.- Notification in the Official Gazette of the Federation.
R.F.C.
Name, denomination or corporate 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
CAM120703914
CAMPORTADOR,
S.P.R. DE R.L.
DE C.V.
500-05-2024-13073 dated July 08
2024
Central Administration of
Strategic Audit
August 09, 2024
August 12, 2024
2
CEK210703AHA
CONSTRUCCIONES EKT, S.A. DE
C.V.
500-05-2024-13073 dated July 08
2024
Central Administration of
Strategic Audit
August 09, 2024
August 12, 2024
3
SVE150305JK2
SUCCESS 21 ENTERPRISES, S.A.
DE C.V.
500-05-2024-12759 dated June 10
2024
Central Administration of
Strategic Audit
July 05, 2024
July 08, 2024
Section D.- Notification of the definitive RESOLUTION office according to the fourth paragraph of Article 69-B of the
Federal Tax Code.
R.F.C.
Name, denomination or corporate name of the
Taxpayer
Number and date of definitive resolution
Issuing Authority of the definitive resolution
Means of notification to the taxpayer
Authority's files
Personal notification
Notification via Tax Box
Date of fixing in the files 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
CAM120703914
CAMPORTADOR,
S.P.R. DE R.L. DE C.V.
500-05-2024-18788 dated November 05
2024
Central Administration of
Strategic Audit
November 11,
2024
November 12, 2024
2
CEK210703AHA
CONSTRUCCIONES
EKT, S.A. DE C.V.
500-05-2024-18789 dated November 05
2024
Central Administration of
Strategic Audit
November 11,
2024
November 12, 2024
3
SVE150305JK2
SUCCESS 21
ENTERPRISES, S.A.
DE C.V.
500-74-05-03-01-
2024-3220 dated
October 14, 2024
Decentralized Administration of
Fiscal Audit of
Federal District "4"
October 18,
2024
October 21, 2024
Section E.- Additional data of the taxpayers.
R.F.C.
Name, denomination or corporate name of the Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
1
CAM120703914
CAMPORTADOR, S.P.R. DE R.L. DE
C.V.
Guadalajara, Jalisco
Wholesale trade of fresh fruits and vegetables
Absence of Assets, Absence of Personnel,
No
Material Capacity
2
CEK210703AHA
CONSTRUCCIONES EKT, S.A. DE C.V.
Salvador Alvarado, Sinaloa
Construction of urbanization works
Absence of Assets, Absence of Personnel,
No
Material Capacity
3
SVE150305JK2
SUCCESS 21 ENTERPRISES, S.A. DE
C.V.
Querétaro, Querétaro
Construction of multifamily housing
Absence of Assets, Absence of Personnel, Lack of Infrastructure, No Material Capacity
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The links and the sentences they come from (3)
- Issued under
- Internal Regulations of the Tax Administration Service published in the Official Gazette of the Federation on August 24, 2015Not in RegAlert
“1, 2, first paragraphs, 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 Reg…”
- Law of the Tax Administration Service, published in the Official Gazette of the Federation on December 15, 1995Not in RegAlert
“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”
- Regulation of 2016Not in RegAlert
“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”
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