Regulatory Alerts2025-04-04 | DOF 5754063Added
Notice 500-05-2025-5870 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code and Obtained Favorable Resolutions
The Central Administration of Strategic Auditing of the Tax Administration Service informs that the tax procedures under Article 69-B of the Federal Tax Code against 14 specific taxpayers have been left without effect following favorable judicial or administrative resolutions. These taxpayers, who were previously notified of presumption notices regarding the non-existence of operations backed by fiscal receipts, successfully challenged the acts through nullity trials or administrative revocation appeals. The document lists the taxpayers' details, the specific resolutions declaring the acts null or unsubstantiated, and the authorities that issued them. The notice clarifies that this outcome does not exempt the taxpayers from responsibility regarding other fiscal receipts issued without adequate assets, personnel, or infrastructure.
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DOF: 04/04/2025
OFFICE 500-05-2025-5870 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 or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the judicial or administrative body left the said act without effect.
A seal with the National Coat of Arms appears on 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 Auditing.
OFFICE: 500-05-2025-5870
Subject: Communication of 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 (CFF) or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the judicial or administrative body left the said act without effect.
This Central Administration of Strategic Auditing, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on the provisions of Article 16, first paragraph of the Political Constitution of the United Mexican States; Articles 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; Articles 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 the provisions of the first paragraph of the First Transitory Article of said Regulations, and reformed by Decree reforming 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, in force from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, fraction I, subsection a), of the Agreement by which various powers are delegated to 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 the provisions of the First Transitory Article of said Agreement; in Articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Federal Tax Code, informs you as follows:
That to the taxpayers listed below, a Notice of Presumption of non-existence of operations backed by certain fiscal receipts issued by them was notified at the time, 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 aforementioned taxpayers were notified of the final resolution as indicated below:
Notification to taxpayers of the OFFICE OF THE FINAL RESOLUTION.
No.
R.F.C.
Name, denomination or corporate name of the Taxpayer
Number and date of the final resolution office
Means of notification to the taxpayer
Authority's Stands
Personal Notification
Tax Box
Date of posting
on the stands
of the Fiscal
Authority
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
Date on
which it
was notified in
Tax
Box
Date on which
the notification
took effect
01
ACI120209FE8
ANALISIS CULTURAL E INTELECTUAL
DE PERSONAL, S.A. DE C.V.
500-18-00-07-01-2019-2547 dated May 16,
2019
May 22,
2019
May 23, 2019
02
AFO120504BN0
ALTA FORMACION OPERACIONAL, S.A.
DE C.V.
500-44-00-00-00-2020-08418 dated September 24,
2020
September 28,
2020
September 29,
2020
03
AIA170223AN4
ASESORIA INTEGRAL APORTA, S.A.
DE C.V.
500-04-00-00-00-2020-25267 dated October 12,
2020
October 16,
2020
October 19,
2020
04
CCA161021LV5
C3 CORPORATIVO AVANTE, S.A. DE
C.V.
500-05-2021-17409 dated May 20, 2021
May 27,
2021
May 28, 2021
05
JCP120601KV8
JC3 CONSTRUCCIONES Y
PROYECTOS, SOCIEDAD ANONIMA DE
CAPITAL VARIABLE
500-56-00-04-01-2021-00461 dated January 26,
2021
February 02,
2021
February 03, 2021
06
LME160304926
LASTRA MERCHANDISING, S.A. DE
C.V.
500-39-00-04-01-2021-5394 dated June 21,
2021
June 25,
2021
June 28, 2021
07
LOPM870909LX2
LOYA PRIETO MYRNA
500-21-00-04-02-2019-1292 dated April 09,
2019
May 06,
2019
May 29, 2019
08
MEZS840315KZ0
MENDEZ ZAMARRONI SERGIO
500-47-00-07-02-00-2020-005510 dated
November 20, 2020
November 26,
2020
November 27,
2020
09
NAPD850627MN0
NAVARRO PEREZ DANIEL
500-25-00-06-03-2020-15912 dated December 15,
2020
January 11,
2021
January 12, 2021
10
NJT140516A28
NI JAU TEXTILES, S.A. DE C.V.
500-05-2021-11002 dated May 11, 2021
May 17,
2021
May 18, 2021
11
SAC151201KI5
SERVICIOS ADMINISTRATIVOS
CAPRESSI, S.A. DE C.V.
500-32-00-04-01-2020-01741 dated March 24,
2020
March 25,
2020
March 26, 2020
12
SCO160616C9A
SPREDE CONSULTORES,
S.A. DE C.V.
500-05-2020-28794 dated December 10,
2020
December 10,
2020
December 11,
2020
13
SICV730101JF3
SILVA DE LA CRUZ VICTOR MANUEL
500-21-00-04-02-2019-1291 dated April 09,
2019
May 06,
2019
May 29, 2019
14
VOS120614SR6
VALUE ORIENTATED SERVICES VOS,
S.A. DE C.V.
500-05-2020-7638 dated February 07, 2020
February 11,
2020
February 12,
2020
Additional data of the taxpayers.
No.
R.F.C.
Name, denomination or corporate name of the
Taxpayer
Fiscal Address
Preponderant Activity
Reason for the Procedure
01
ACI120209FE8
ANALISIS CULTURAL E INTELECTUAL DE
PERSONAL, S.A. DE C.V.
VERACRUZ, VERACRUZ
ACCOUNTING AND AUDITING SERVICES
Absence of assets
Lack of
infrastructure
02
AFO120504BN0
ALTA FORMACION OPERACIONAL, S.A.
DE C.V.
SAN SEBASTIÁN TUTLA, OAXACA
PERMANENT PERSONNEL SUPPLY
Absence of assets
Absence
of personnel
Lack of
infrastructure
No material
capacity
03
AIA170223AN4
ASESORIA INTEGRAL APORTA, S.A. DE
C.V.
CHIHUAHUA, CHIHAUHUA
CONSULTING SERVICES IN
ADMINISTRATION
Absence of assets
Absence
of personnel
04
CCA161021LV5
C3 CORPORATIVO AVANTE,
S.A. DE C.V.
ALCALDÍA ÁLVARO OBREGÓN,
CITY
OF MEXICO
LAW FIRMS
Absence of assets
Absence
of personnel
05
JCP120601KV8
JC3 CONSTRUCCIONES Y PROYECTOS,
SOCIEDAD ANONIMA DE CAPITAL
VARIABLE
NOGALES, SONORA
OTHER INSTALLATIONS AND EQUIPMENT
IN CONSTRUCTIONS
Absence of assets
Absence
of personnel
Lack of
infrastructure
06
LME160304926
LASTRA MERCHANDISING, S.A. DE C.V.
CUAUHTÉMOC, CITY OF
MEXICO
OTHER WHOLESALE COMMERCE INTERMEDIARIES
Absence of assets
Absence
of personnel
Lack of
infrastructure
No material
capacity
07
LOPM870909LX2
LOYA PRIETO MYRNA
CHIHUAHUA, CHIHUAHUA
RENTAL OF EQUIPMENT FOR LIFTING,
MOVING AND ACCOMMODATING MATERIALS
Absence of assets
Absence
of personnel
Lack of
infrastructure
08
MEZS840315KZ0
MENDEZ ZAMARRONI SERGIO
SAN JUAN DEL RÍO, QUERÉTARO
OTHER CIVIL ENGINEERING CONSTRUCTIONS
OR HEAVY WORK
Absence of assets
Absence
of personnel
Lack of
infrastructure
09
NAPD850627MN0
NAVARRO PEREZ DANIEL
LEÓN, GUANAJUATO
SALARIED AND SHAREHOLDER PARTNER
Absence of assets
Absence
of personnel
10
NJT140516A28
NI JAU TEXTILES, S.A. DE C.V.
TULTITLAN, STATE OF MEXICO
WHOLESALE TRADE OF WHITE GOODS
Absence of assets
Absence
of personnel
11
SAC151201KI5
SERVICIOS ADMINISTRATIVOS
CAPRESSI, S.A. DE C.V.
ZAPOPAN, JALISCO
OTHER SUPPORT SERVICES FOR
BUSINESSES
Absence of assets
Absence
of personnel
Lack of
infrastructure
12
SCO160616C9A
SPREDE CONSULTORES,
S.A. DE C.V.
NAUCALPAN DE JUÁREZ, STATE
OF MEXICO
OTHER PROFESSIONAL, SCIENTIFIC AND
TECHNICAL SERVICES
Absence of assets
Absence
of personnel
13
SICV730101JF3
SILVA DE LA CRUZ VICTOR MANUEL
CHIHUAHUA, CHIHAUHUA
OTHER CIVIL ENGINEERING CONSTRUCTIONS
OR HEAVY WORK
Absence of assets
Absence
of personnel
Lack of
infrastructure
14
VOS120614SR6
VALUE ORIENTATED SERVICES VOS, S.A.
DE C.V.
MOTERREY, NUEVO LEÓN
OTHER WHOLESALE COMMERCE INTERMEDIARIES
Absence of assets
Absence
of personnel
Therefore, the name or corporate name of the taxpayers
to whom the aforementioned resolutions were notified, 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.
R.F.C.
Name, denomination or corporate name of the Taxpayer
Number and date of the office containing in Global
Final List
Date of publication in the
Official Gazette of the Federation
01
ACI120209FE8
ANALISIS CULTURAL E INTELECTUAL DE PERSONAL, S.A.
DE C.V.
This taxpayer was not published in the definitive global lists
02
AFO120504BN0
ALTA FORMACION OPERACIONAL,
S.A. DE C.V.
500-05-2021-5055 dated February 09, 2021
February 22, 2021
03
AIA170223AN4
ASESORIA INTEGRAL APORTA, S.A. DE C.V.
500-05-2021-5061 dated February 09, 2021
February 24, 2021
04
CCA161021LV5
C3 CORPORATIVO AVANTE, S.A. DE C.V.
500-05-2021-15535 dated July 14, 2021
August 19, 2021
05
JCP120601KV8
JC3 CONSTRUCCIONES Y PROYECTOS, SOCIEDAD
ANONIMA DE CAPITAL VARIABLE
500-05-2021-10803 dated March 25, 2021
April 08, 2021
06
LME160304926
LASTRA MERCHANDISING, S.A. DE C.V.
500-05-2021-26102 dated October 15, 2021
November 04, 2021
07
LOPM870909LX2
LOYA PRIETO MYRNA
500-05-2019-27749 dated August 27, 2019
September 25, 2019
08
MEZS840315KZ0
MENDEZ ZAMARRONI SERGIO
500-05-2021-5303 dated March 04, 2021
March 18, 2021
09
NAPD850627MN0
NAVARRO PEREZ DANIEL
500-05-2021-6723 dated March 16, 2021
March 29, 2021
10
NJT140516A28
NI JAU TEXTILES, S.A. DE C.V.
500-05-2021-15538 dated July 15, 2021
August 18, 2021
11
SAC151201KI5
SERVICIOS ADMINISTRATIVOS CAPRESSI, S.A. DE C.V.
500-05-2020-13612 dated May 28, 2020
June 25, 2020
12
SCO160616C9A
SPREDE CONSULTORES, S.A. DE C.V.
500-05-2021-5303 dated March 04, 2021
March 18, 2021
13
SICV730101JF3
SILVA DE LA CRUZ VICTOR MANUEL
500-05-2019-27749 dated August 27, 2019
September 25, 2019
14
VOS120614SR6
VALUE ORIENTATED SERVICES VOS,
S.A. DE C.V.
500-05-2020-13568 dated May 13, 2020
June 29, 2020
Disagreeing with the individual presumption notice or the final resolution notice, they filed means of defense, which were concluded with the following resolutions or judgments:
No.
R.F.C.
Name, denomination or corporate
name of the Taxpayer
Means of defense
Date of the
Resolution or
final judgment
Authority that resolved
Sense and/or effect of the resolution or
final judgment
01
ACI120209FE8
ANALISIS CULTURAL E
INTELECTUAL DE PERSONAL,
S.A. DE C.V.
Nullity Trial 341/21-
13-01-3
April 28,
2021
Regional Gulf Chamber of the
Federal Administrative Justice Tribunal
The nullity of the challenged resolution 500-18-00-07-01-2019-2547 dated
May 16, 2019, issued by the
Concentrated Administration of Fiscal Audit of Colima "1" is declared.
02
AFO120504BN0
ALTA FORMACION
OPERACIONAL,
S.A. DE C.V.
Nullity Trial 21/279-
24-01-02-08-OL
March 01,
2023
Specialized Mixed Chamber in
Online Trials and in Environmental
and Regulation Matters of the
Federal Fiscal and Administrative Justice Tribunal
The absolute nullity of the challenged resolution 600-44-00-00-00- 2020-2655 dated December 07, 2020, issued by the Concentrated Legal Administration of Oaxaca "1", as well as, of the originally challenged 500-44- 00-00-00-2020-08418 of September 24, 2020, signed by the Concentrated Administration of Fiscal Audit of Oaxaca "1" is declared.
03
AIA170223AN4
ASESORIA INTEGRAL APORTA,
S.A. DE C.V.
Nullity Trial 2554/21-
04-01-5-OT
November 07, 2024
Regional North-Center I Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged resolution 600-21-00-01-00- 2021-0967 dated April 09, 2021, issued by the Concentrated Legal Administration of Chihuahua "1", by which the Online Administrative Revocation Appeal RRL2020010460 was resolved, as well as, of the originally challenged 500-04-00-00-00- 2020-25267 of October 12, 2020, signed by the Central Administration of Verification and Evaluation of Federative Entities in Fiscal Coordination Matters is declared.
04
CCA161021LV5
C3 CORPORATIVO AVANTE, S.A.
DE C.V.
Nullity Trial 22166/
22-17-02-7
May 15,
2024
Second Metropolitan Regional Chamber of the Federal Administrative Justice Tribunal
The nullity of the ficta confirmative resolution issued on the Online Administrative Revocation Appeal RRL2021008628, as well as of the originally challenged 500-05-2021-17409 of May 20, 2021, signed by the Central Administration of Strategic Auditing is declared.
05
JCP120601KV8
JC3 CONSTRUCCIONES Y
PROYECTOS, SOCIEDAD
ANONIMA DE CAPITAL
VARIABLE
Nullity Trial 440/21-
02-01-2
February 01,
2023
Regional Northeast II Chamber of the Federal Administrative Justice Tribunal
The nullity of the challenged resolution 500-56-00-04-01-2021-00461 dated January 26, 2021, issued by the Concentrated Administration of Fiscal Audit of Sonora "3" is declared.
06
LME160304926
LASTRA MERCHANDISING,
S.A.
DE C.V.
Nullity Trial 19698/
23-17-11-6
June 26,
2024
Eleventh Metropolitan Regional Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged acts is declared.
07
LOPM870909LX2
LOYA PRIETO MYRNA
Nullity Trial 1301/24-
04-01-3-OT
November 19, 2024
Regional North-Center I Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged resolution 500-21-00-04-02- 2019-1292 dated April 09, 2019, issued by the Concentrated Administration of Fiscal Audit of Chihuahua "1" is declared.
08
MEZS840315KZ0
MENDEZ ZAMARRONI SERGIO
Nullity Trial 1089/21-
09-01-3-OT
April 04,
2023
Regional Center II Chamber of the Federal Administrative Justice Tribunal
The nullity of the challenged resolution 600-47-03-RR-05-2021-0757 dated March 31, 2021, issued by the Concentrated Legal Administration of Querétaro "1", by which the Online Administrative Revocation Appeal RRL2021000873 was resolved, regarding the confirmation of the originally challenged resolution is declared.
Likewise, the absolute nullity of the originally challenged resolution 500- 47-07-02-00-2020-005510 of November 20, 2020, issued by the Concentrated Administration of Fiscal Audit of Querétaro "1" is declared.
09
NAPD850627MN0
NAVARRO PEREZ DANIEL
Nullity Trial 2137/21-
30-01-6-OT
July 05,
2022
Regional Center IV and Auxiliary Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged resolution 500-25-00-06-03- 2020-15912 dated December 15, 2020, issued by the Concentrated Administration of Fiscal Audit of Guanajuato "2" is declared.
10
NJT140516A28
NI JAU TEXTILES,
S.A. DE C.V.
Online Revocation Appeal RRL2021007829
October 19,
2021
Concentrated Legal Administration of
Mexico "2"
The challenged resolution 500-05-2021-11002 dated May 11, 2021, issued by the Central Administration of Strategic Auditing is left unsubstantiated, and a new resolution is ordered to be issued.
11
SAC151201KI5
SERVICIOS ADMINISTRATIVOS
CAPRESSI, S.A. DE C.V.
Nullity Trial 9927/22-
17-01-5
November 03, 2023
First Metropolitan Regional Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged resolution 600-32-2022-01584 dated March 03, 2022, issued by the Concentrated Legal Administration of Jalisco "3", by which the Online Administrative Revocation Appeal RRL2020003727 was resolved, as well as of the originally challenged 500-32-00-04-01- 2020-01741 of March 24, 2020, signed by the Concentrated Administration of Fiscal Audit of Jalisco "3" is declared.
12
SCO160616C9A
SPREDE CONSULTORES, S.A.
DE C.V.
Nullity Trial 1007/21-
02-01-7 and accumulated
1510/21-02-01-8
December 01, 2022
Regional Northwest II Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged Negative Ficta resolution attributed to the Concentrated Legal Administration of Mexico "2", by which the Online Administrative Revocation Appeal RRL2021001602 was resolved, as well as of the originally challenged 500-05- 2020-28794 of December 10, 2020, signed by the Central Administration of Strategic Auditing is declared.
13
SICV730101JF3
SILVA DE LA CRUZ VICTOR
MANUEL
Nullity Trial 1137/24-
04-01-3-OT
November 19, 2024
Regional North-Center I Chamber of the Federal Administrative Justice Tribunal
The absolute nullity of the challenged resolution 500-21-00-04-02- 2019-1291 dated April 09, 2019, issued by the Concentrated Administration of Fiscal Audit of Chihuahua "1" is declared.
14
VOS120614SR6
VALUE ORIENTATED SERVICES
V OS, S.A. DE C.V.
Nullity Trial 20/1715-
24-01-03-06-OL
April 11,
2024
Specialized Mixed Chamber in Online Trials and in Environmental and Regulation Matters of the Federal Fiscal and Administrative Justice Tribunal
The absolute nullity of the challenged resolution 600-41-2020-3065 dated June 17, 2020, issued by the Concentrated Legal Administration of Nuevo León "1", by which the Online Administrative Revocation Appeal RRL2020002531 was resolved, as well as of the originally challenged 500-05- 2020-7638 of February 07, 2020, signed by the Central Administration of Strategic Auditing is declared.
In view of the above, it is informed 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 become without effect.
Finally, it is informed that the fact that the aforementioned taxpayers have obtained a favorable resolution against the presumption notice and/or final 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, whereby the powers of the tax authority are reserved.
Sincerely.
Mexico City, February 11, 2025. - In substitution for the absence of the Central Administrator of Strategic Auditing, of the Coordinator of Strategic Auditing, of the Administrator of Strategic Auditing "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 Auditing "7". - Rubric.
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