Regulatory Alerts2026-04-30 | DOF 5786351Added · Updated
Notice 500-05-2026-11155 Communicating List of Taxpayers Who Filed Legal Challenges Against Presumption Notices Under Article 69-B of the Federal Tax Code
The Servicio de Administración Tributaria communicates that tax proceedings under Article 69-B of the Federal Tax Code against 11 specific taxpayers have been rendered without effect due to favorable judicial or administrative resolutions. The affected taxpayers, including Aranda Neri Miguel and Flora Food Manufacturing Mexico, successfully challenged presumption notices regarding the non-existence of operations supported by fiscal receipts. While the specific acts are annulled or left without effect, the tax authority retains its powers to investigate other fiscal receipts issued by these entities lacking the necessary assets, personnel, or infrastructure.
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DOF: 30/04/2026
OFFICE 500-05-2026-11155 through which 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 is communicated, and once resolved, the jurisdictional or administrative body left the referred act without effect.
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 Auditing.
OFFICE: 500-05-2026-11155
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 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.
The Central Administration of Strategic Auditing, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is established in Article 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 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, 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; as well as in Articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Federal Tax Code, it communicates the following:
That to the taxpayers listed below, at some point, they were notified of a Presumption Notice of non-existence of operations supported by certain fiscal receipts they issued, 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 of reference were notified of the definitive resolution as indicated below:
Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.
No.
R.F.C.
Name, denomination or
social reason of the
Taxpayer
Number and date
of office of
definitive resolution
Means of notification to the taxpayer
Authority's Stands
Personal Notification
Tax Box
Date of fixation
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 of
notification
Date on which
the notification
took effect
01
AANM951213N83
ARANDA NERI MIGUEL
500-54-00-02-01-
2020-0575 of April 01
2020
April 17 of
2020
May 14 of
2020
02
BERJ860315K29
BELTRAN REYES JUAN
DIEGO
500-27-00-08-02-
2021-05890 of June 25
2021
August 18 of
2021
August 30 of
2021
03
CDI100429716
CONSTRUCTIONS AND
REAL ESTATE DEVELOPMENTS
BLAESCO,
S.A. DE C.V.
500-04-00-00-00-
2020-25276 of October 21
2020
November 12 of
2020
December 08 of
2020
04
CLE190426UG5
CREATIVE LEAP, S.A. DE C.V.
500-05-2024-
18508 of September 04
2024
September 05 of
2024
September 06 of
2024
05
IIP1401136P9
INVERPAT INVERSIONES
PATRIMONIALES, S.C.
500-32-00-05-05-
2021-5659 of July 06
2021
July 12 of
2021
July 13 of
2021
06
MAS160701IS4
MA'AIKATAN SERVICES, S.A.
DE C.V.
500-05-2021-5017
of February 11
2021
February 11 of
2021
February 12 of
2021
07
PPN0102153H0
PROMOTERS
PROFESSIONAL OF THE
NORTHWEST, S.A. DE C.V.
500-52-00-05-00-
2019-04838 of May 14
2019
May 15 of
2019
May 16 of
2019
08
PRO1210108PA
PROTEXER, S. DE R.L. DE
C.V.
500-72-02-00-04-
2021-12697 of August 23
2021
August 27 of
2021
August 30 of
2021
09
REN1205253E8
REFACCIONARIA ENDECKS,
S.A. DE C.V.
500-44-00-00-00-
2019-09053 of October 15
2019
November 04 of
2019
November 05 of
2019
10
SSD180416GS8
FLORA FOOD
MANUFACTURING MEXICO, S.
DE R.L. DE C.V. (before
UPFIELD MEXICO 2, S. DE
R.L. DE C.V.)
500-05-2025-
10896 of April 02
2025
April 02 of
2025
April 03 of
2025
11
STI1106171W2
TOTAL SOLUTION AND
ACCOUNTING INNOVATION
TRUMBS, S.A. DE C.V.
500-74-06-03-02-
2021-5943 of June 14
2021
June 18 of
2021
June 21 of
2021
Additional data of the taxpayers.
No.
R.F.C.
Name, denomination or social reason of the
Taxpayer
Fiscal Address
Preponderant Activity
Reason for the Procedure
01
AANM951213N83
ARANDA NERI MIGUEL
Hermosillo, Sonora
Sowing, cultivation and harvesting of other crops
Absence of Assets
Absence of
Personnel
02
BERJ860315K29
BELTRAN REYES JUAN DIEGO
Taxco de Alarcón, Guerrero
Metalwork and jewelry of metals and precious stones other than gold
Absence of Assets
Absence of
Personnel
Without Material Capacity
03
CDI100429716
CONSTRUCTIONS AND DEVELOPMENTS
REAL ESTATE BLAESCO, S.A. DE C.V.
Zihuatanejo, Guerrero
Other Civil Engineering Constructions or heavy work
Absence of Assets
Absence of
Personnel
04
CLE190426UG5
CREATIVE LEAP, S.A. DE C.V.
Pachuca de Soto, Hidalgo
Law Firms
Absence of Assets
Absence of
Personnel
Without Material Capacity
05
IIP1401136P9
INVERPAT INVERSIONES PATRIMONIALES, S.C.
Zapopan, Jalisco
Other wholesale trade intermediaries
Absence of Assets
Absence of
Personnel
06
MAS160701IS4
MA ' AIKATAN SERVICES, S.A. DE C.V.
Benito Juárez, Quintana Roo
Other services related to transport
Absence of Assets
Absence of
Personnel
07
PPN0102153H0
PROMOTERS PROFESSIONAL OF THE
NORTHWEST, S.A. DE C.V.
Zapopan, Jalisco
Business administration services
Absence of Assets
Absence of
Personnel
08
PRO1210108PA
PROTEXER, S. DE R.L. DE C.V.
UNKNOWN
Wholesale trade of clothing
Absence of Assets
Absence of
Personnel
09
REN1205253E8
REFACCIONARIA ENDECKS, S.A. DE C.V.
Santa Lucia del Camino,
Oaxaca
Retail trade of new parts and spare parts for
cars, pickups and trucks
Absence of Assets
Absence of
Personnel
10
SSD180416GS8
FLORA FOOD MANUFACTURING MEXICO, S. DE
R.L. DE C.V. (before UPFIELD MEXICO 2, S. DE
R.L. DE C.V.)
Huixquilucan de Degollado,
State of Mexico
Elaboration of edible vegetable oils and fats
Absence of Assets
Absence of
Personnel
Without Material Capacity
11
STI1106171W2
TOTAL SOLUTION AND ACCOUNTING INNOVATION
TRUMBS, S.A. DE C.V.
Miguel Hidalgo, Mexico City
Administration consulting services
Absence of Assets
Lack of
Infrastructure
For the above, the name or social reason 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 social reason of the Taxpayer
Number and date of office that contains in List
Global Definitive
Date of publication in the Official Gazette of the
Federation
01
AANM951213N83
ARANDA NERI MIGUEL
500-05-2021-5054 of February 09, 2021
February 22, 2021
02
BERJ860315K29
BELTRAN REYES JUAN DIEGO
500-05-2021-26226 of November 17, 2021
December 10, 2021
03
CDI100429716
CONSTRUCTIONS AND DEVELOPMENTS REAL ESTATE BLAESCO,
S.A. DE C.V.
500-05-2021-5205 of March 03, 2021
March 22, 2021
04
CLE190426UG5
CREATIVE LEAP, S.A. DE C.V.
500-05-2024-18776 of October 28, 2024
November 29, 2024
05
IIP1401136P9
INVERPAT INVERSIONES PATRIMONIALES, S.C.
500-05-2021-26042 of September 27, 2021
October 18, 2021
06
MAS160701IS4
MA ' AIKATAN SERVICES, S.A. DE C.V.
500-05-2021-6937 of April 26, 2021
May 13, 2021
07
PPN0102153H0
PROMOTERS PROFESSIONAL OF THE NORTHWEST, S.A. DE C.V.
500-05-2019-36127 of November 15, 2019
December 06, 2019
08
PRO1210108PA
PROTEXER, S. DE R.L. DE C.V.
500-05-2021-26136 of October 25, 2021
November 10, 2021
09
REN1205253E8
REFACCIONARIA ENDECKS, S.A. DE C.V.
500-05-2020-3645 of January 15, 2020
February 14, 2020
10
SSD180416GS8
FLORA FOOD MANUFACTURING MEXICO, S. DE R.L. DE C.V.
(before UPFIELD MEXICO 2, S. DE R.L. DE C.V.)
This taxpayer was not published in the definitive global lists.
11
STI1106171W2
TOTAL SOLUTION AND ACCOUNTING INNOVATION TRUMBS, S.A. DE
C.V.
500-05-2021-25950 of August 25, 2021
September 21, 2021
Dissatisfied with the individual presumption office or definitive resolution office, they filed means of defense, which were concluded with the following resolutions or sentences:
No.
R.F.C.
Name, denomination or social
reason of the Taxpayer
Means of defense
Date of the
Resolution or
firm sentence
Authority that resolved
Sense and/or effect of the resolution or firm sentence
01
AANM951213N83
ARANDA NERI MIGUEL
Nullity Trial 1977/24-
02-01-3
August 20, 2025
Regional Chamber in Sonora of the
Federal Tribunal of Administrative
Justice
The nullity of the challenged resolution 500-54- 00-02-01-2020-0575 of April 01, 2020, issued by the
Concentrated Administration of Fiscal Audit of Sonora "1" is declared plain and simple.
02
BERJ860315K29
BELTRAN REYES JUAN DIEGO
Nullity Trial 570/22-
14-01-3
November 23, 2022
Regional Chamber of the Pacific and
Auxiliary of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500-27- 00-08-02-2021-05890 of June 25, 2021, issued by the
Concentrated Administration of Fiscal Audit of Guerrero "1" is declared plain and simple.
03
CDI100429716
CONSTRUCTIONS AND
DEVELOPMENTS
REAL ESTATE BLAESCO, S.A.
DE C.V.
Nullity Trial 8/22-14-
01-9
November 18, 2022
Regional Chamber of the Pacific and
Auxiliary of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500-04- 00-00-00-2020-25276 of October 21, 2020, issued by the
Central Administration of Verification and Evaluation of Entities
Federative in Matters of Fiscal Coordination is declared plain and simple.
04
CLE190426UG5
CREATIVE LEAP, S.A. DE C.V.
Nullity Trial 22381/
24-17-14-7
April 09, 2025
Tenth Regional Metropolitan Chamber of the
Federal Tribunal of Administrative
Justice
The nullity of the challenged resolution 500-05- 2024-18508 of September 04, 2024, issued by the
Central Administration of Strategic Auditing is declared plain and simple.
05
IIP1401136P9
INVERPAT INVERSIONES
PATRIMONIALES, S.C.
Nullity Trial 6528/24-
07-02-4
November 21, 2025
Second Regional Chamber in
Jalisco of the Federal Tribunal of
Administrative Justice
The nullity of the ficta confirmative issued to the
Administrative Recourse of Revocation Online RRL2021010769,
promoted before the Concentrated Administration Juridical of
Jalisco "3", as well as of the originally challenged
500-32-00-05-05-2021-5659 of July 06, 2021, signed by the
Concentrated Administration of Fiscal Audit of Jalisco "3" is declared.
06
MAS160701IS4
MA'AIKATAN SERVICES, S.A.
DE C.V.
Nullity Trial 976/22-
02-01-5
January 23, 2023
Regional Chamber of the Northwest
II of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 600-49-2022-0748
of March 10, 2022, issued by the Administration
Concentrated Juridical of Quintana Roo "2", which resolved the
Administrative Recourse of Revocation Online RRL2021004024,
as well as, of the originally challenged 500-05-2021-5017 of February 11,
2021, signed by the Central Administration of
Strategic Auditing is declared.
07
PPN0102153H0
PROMOTERS
PROFESSIONAL OF THE
NORTHWEST, S.A. DE C.V.
Nullity Trial 4076/20-
07-01-2
September 07, 2023
First Regional Chamber of
Occident of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 600-52- 2020-00295 of February 13, 2020, issued by the Administration
Concentrated Juridical of Sinaloa "2", which resolved the Administrative
Recourse of Revocation Online RRL2019005570, as well as,
of the originally challenged 500-52-00-05-00-2019-04838 of May 14,
2019, signed by the Concentrated Administration of
Fiscal Audit of Sinaloa "2" is declared plain and simple.
08
PRO1210108PA
PROTEXER, S. DE R.L. DE C.V.
Nullity Trial 198/22-
09-01-1-OT
October 15, 2025
Regional Chamber in Querétaro
of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500-72-02-00-04- 2021-12697 of August 23, 2021, issued by the Administration
Concentrated of Fiscal Audit of the Federal District "2" is declared.
09
REN1205253E8
REFACCIONARIA ENDECKS,
S.A. DE C.V.
Nullity Trial 35/20-
15-01-2
March 03, 2025
Regional Chamber of the Southeast
of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 500-44-00-00-00- 2019-09053 of October 15, 2019, issued by the
Concentrated Administration of Fiscal Audit of Oaxaca "1" is declared.
10
SSD180416GS8
FLORA FOOD
MANUFACTURING MEXICO, S.
DE R.L. DE C.V. (before UPFIELD
MEXICO 2, S. DE R.L. DE C.V.)
Administrative Recourse of Revocation
RRL2025005780,
RRL2025010286 and
accumulated
November 07, 2025
Concentrated Administration
Juridical of Mexico " 2 "
The resolution 500-05-2025-10896 of April 02, 2025, issued by the Central Administration of Strategic
Auditing is left unsubstantiated, for the effect that said fiscal authority, analyzes and
values each of the proofs exhibited in that administrative instance
by the appellant and issues a new resolution and determines with
freedom of jurisdiction what corresponds in law.
11
STI1106171W2
TOTAL SOLUTION AND
ACCOUNTING INNOVATION
TRUMBS, S.A. DE C.V.
Nullity Trial 25722/
22-17-08-9
September 03, 2024
Eighth Regional Metropolitan Chamber of the Federal Tribunal of
Administrative Justice
The nullity of the challenged resolution 600-74-00-02-00- 2022-12491 of August 29, 2022, issued by the Administration
Concentrated Juridical of the Federal District "4", which resolved the
Administrative Recourse of Revocation Online RRL2021009664,
as well as, of the originally challenged 500-74-06-03-02-2021-5943
of June 14, 2021, signed by the Administration
Concentrated of Fiscal Audit of the Federal District "4" is declared.
In view of the above, it is communicated that, as a consequence of the means of defense indicated in preceding paragraphs, the proceedings of Article 69-B of the Federal Tax Code, followed against those taxpayers, have
remained without effect.
Finally, it is informed that the fact that the aforementioned taxpayers
have obtained a favorable resolution in
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 supported such receipts,
for which reason, the powers of the fiscal authority are left safe.
Respectfully.
Mexico City, February 20, 2026.- Central Administrator of Strategic Auditing, L.C. Rubén Martín
López Rodríguez.- Rubric.
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