Notice 900-04-00-00-00-2025-349 Communicating the Definitive Global List Under Article 69-B Bis of the Federal Tax Code

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DOF: 30/05/2025

OFFICE 900-04-00-00-00-2025-349 communicating the definitive global list under Article 69-B Bis, ninth paragraph, of the Federal Tax Code.

At the margin, a seal with the National Coat of Arms, stating: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.-

Tax Administration Service.- General Administration of Large Taxpayers.- Central Administration for Auditing

Various Large Taxpayers.

OFFICE: 900-04-00-00-00-2025-349.

Taxpayer ID (R.F.C.): BER160621KN5.

FOLIO: 7351587.

SUBJECT: COMMUNICATION OF THE DEFINITIVE GLOBAL LIST UNDER ARTICLE 69-B BIS, NINTH PARAGRAPH OF THE FEDERAL TAX CODE.

The Central Administration for Auditing Various Large Taxpayers, headquartered in Mexico City, attached to the General Administration of Large Taxpayers, of the Tax Administration Service, based on the provisions of Articles 16, first paragraph, of the Political Constitution of the United Mexican States; 17 and 31, fractions XI and XXXIV of the Organic Law of the Federal Public Administration; 1, 2, 3, 4, 7, fractions VII, XII and XVIII and 8, fraction III of the Tax Administration Service Law, 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 V, subsection d) and second paragraph, 5, first paragraph, 13, fraction VI, and 28, last paragraph, numeral 4, of the Internal Regulations of the Tax Administration Service published in the Official Gazette of the Federation on August 24, 2015, in effect 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 effect from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Third Article, fraction I, subsection a) of the Agreement by which various powers are delegated to public servants of the General Administrations of Federal Fiscal Audit, Foreign Trade Audit, Large Taxpayers and Hydrocarbons of the Tax Administration Service, published in the Official Gazette of the Federation on October 22, 2018, in effect from November 1, 2018, in accordance with the provisions of the Unique Transitory Article of said agreement; in relation to, Articles Eighth, fraction V of the Agreement by which the powers of public servants of the Tax Administration Service are delegated, published in the aforementioned informative medium on September 03, 2020 and Fifth, fraction V of the Agreement by which powers are delegated to public servants of the Tax Administration Service published in the aforementioned informative medium on May 19, 2021; as well as Articles 33, last paragraph, 63 and 69-B Bis, paragraphs first, second, fourth, seventh, ninth and tenth of the Federal Tax Code, informs the following:

As a result of the procedure for presuming the improper transmission of the right to reduce tax losses provided for in Article 69-B Bis, of the Federal Tax Code, the Authority cited in Annex 1, which is an integral part of this office, detected that the taxpayer indicated in said Annex 1 carried out the improper transmission of the right to reduce tax losses.

Having detected such a situation, the aforementioned tax authority, in order to comply with Article 69-B Bis, fourth paragraph of the Federal Tax Code, issued a presumption notice to the taxpayer mentioned in the aforementioned Annex 1, and in said notice the reasons and grounds were indicated by which the taxpayer fell into the hypothesis referred to in the first paragraph of Article 69-B Bis of the Federal Tax Code.

Now, the notice mentioned in the preceding paragraph was notified to the taxpayer in the terms specified in Annex 1, Section A, of this office, which is an integral part of it.

Attending to the provisions of the fourth paragraph of Article 69-B Bis of the Federal Tax Code, in the presumption notice, the tax authority granted the taxpayer a period of twenty business days counted from the last notification made, to make statements and provide the documentation and information they considered pertinent to refute the facts given known through the aforementioned notice, under the warning that if the granted period elapsed without providing the documentation and information and/or what was exhibited, once evaluated, did not refute the facts indicated in the notice of merit, the tax authorities would proceed, in terms of the seventh and ninth paragraphs of Article 69-B Bis of the Federal Tax Code, first to notify them of the definitive resolution, as well as to publish their name, denomination or trade name in the list of taxpayers who did not refute the facts given known and, therefore, would be definitively in the situation referred to in the first paragraph of the aforementioned Article 69-B Bis of the Federal Tax Code.

Once the period indicated in the previous paragraph has elapsed, and in view of the fact that the taxpayer during the period established in the fourth paragraph of Article 69-B Bis of the Federal Tax Code, in exercise of the right provided for in the cited legal provision, presented, through the means indicated in the presumption notice, various information, documentation and arguments, tending to refute the facts given known through said notice mentioned above, said authority proceeded to the admission and valuation of the same.

As a result of the valuation mentioned in the preceding paragraph, the Central Administration for Auditing Various Large Taxpayers considered that the taxpayer did not refute the presumption of the improper transmission of the right to reduce tax losses, so it proceeded to issue the definitive resolution in which it was determined that they did not refute the facts imputed to them, and, therefore, they are definitively in the situation referred to in the first paragraph of Article 69-B Bis of the Federal Tax Code for the reasons exposed in the definitive resolution, which was duly notified to the taxpayer in the terms indicated in Annex 1, Section B of this office.

For the above and, taking into account that the ninth paragraph of Article 69-B Bis of the Federal Tax Code, states that under no circumstances will the list be published before thirty business days after 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 judgment granted in favor of this taxpayer referenced in Annex 1 of this office that orders the suspension or declares the nullity or revocation of the procedure provided for in the referenced article; therefore, with the purpose of giving full compliance to Resolutive Third contained in the aforementioned definitive resolution, referenced in Annex 1, Section B, this Central Administration for Auditing Various Large Taxpayers, attached to the General Administration of Large Taxpayers, of the Tax Administration Service, in support of the tax Authority indicated in Annex 1 of this, proceeds to add the name, denomination or trade name of the taxpayer indicated in Annex 1 of this office, to the list of taxpayers who did not refute the facts imputed to them and therefore, are definitively in the situation referred to in the first paragraph of the aforementioned Article 69-B Bis of the Federal Tax Code, for the reasons and grounds indicated in the definitive resolution notified, a list that will be published on the website of the Tax Administration Service ( www.sat.gob.mx ) as well as in the Official Gazette of the Federation, to confirm, with general effects, the improper transmission of tax losses obtained by the taxpayer who generated them, as well as the impropriety of their reduction by the corresponding taxpayer, just as declared by the tenth paragraph of Article 69-B Bis of the Federal Tax Code; this, since it is in the public interest to inhibit practices tending to erode the income tax base through the improper transmission of tax losses, as well as that society knows who those taxpayers are who carry out this type of operation.

Respectfully,

Mexico City, May 14, 2025. - Central Administrator for Auditing Various Large Taxpayers, L.C. Alejandro Alcides Villalta Ramírez .- Electronic Signature.

Annex 1 Office number 900-04-00-00-00-2025-349 dated May 14, 2025, through which the definitive global list is communicated under Article 69-B Bis, ninth paragraph of the Federal Tax Code, corresponding to the taxpayer who provided documentation and information to refute the presumption referred to in the first paragraph of the aforementioned numeral, but with the same DID NOT refute the facts imputed to them, which is why the DEFINITIVELY the hypothesis referred to in the first paragraph of Article 69-B Bis of the Federal Tax Code was updated, for the effects provided for in the tenth paragraph of the aforementioned numeral.

Section A.- Notification of the PRESUMPTION NOTICE in accordance with paragraphs first, second and fourth of Article 69-B Bis of the Federal Tax Code.

Means of notification to the taxpayer

Taxpayer ID (R.F.C.)

Name, denomination or trade name of the Taxpayer

Number and date of the presumption notice

Authority issuing the individual presumption notice

By Tax Box

Date of notification

Date on which the notification took effect

1

BER160621KN5

BERNABASTOS, S.A. DE

C.V.

900-04-05-00-00-2022-699 dated November 29, 2022

Administration for Auditing Various Large Taxpayers

" 5 "

November 30, 2022

December 01, 2022

Section B.- Notification of the DEFINITIVE RESOLUTION notice in accordance with the seventh paragraph of Article 69-B Bis of the Federal Tax Code.

Taxpayer ID (R.F.C.)

Name, denomination or trade name of the Taxpayer

Number and date of the definitive resolution

Authority issuing the definitive resolution

Notification by Tax Box to the taxpayer

Date of notification

Date on which the notification took effect

1

BER160621KN5

BERNABASTOS, S.A. DE

C.V.

900-04-00-00-00-2023-261 dated July 07, 2023

Central Administration for Auditing Various Large Taxpayers

July 12, 2023

July 13, 2023

Section C.- Additional data of the taxpayer.

Taxpayer ID (R.F.C.)

Name, denomination or trade name of the Taxpayer

Tax Address

Predominant Activity

Reason for the Procedure

1

BER160621KN5

BERNABASTOS, S.A. DE

C.V.

Lázaro Cárdenas 2305, int. Z1 10, Las Torres, Guadalajara, Jalisco.

Rental of Offices, Commercial Premises, Parking Lots and Pensions for automobiles.

Improper transmission of the right to reduce tax losses.

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