Notice 900 04 00 00 00 2026-254: Notification that Operadora Autopistas Nacionales Equivent, S.A. de C.V. Challenged a Presumption Notice and the Jurisdictional Body Annulled the Act

DOF: 05/06/2026

OFFICE 900 04 00 00 00 2026-254 through which it is communicated that Operadora Autopistas Nacionales Equivent, S.A. de C.V. promoted a legal remedy against the presumption notice referred to in the fourth paragraph of Article 69-B Bis of the Federal Tax Code and, once resolved, the jurisdictional body left the referred act without effect.

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 Large Taxpayers.- Central Administration of Audit for Various Large Taxpayers.- Folio: 8322259.

OFFICE: 900 04 00 00 00 2026-254

Subject: It is communicated that Operadora Autopistas Nacionales Equivent, S.A. de C.V. promoted a legal remedy against the presumption notice referred to in Article 69-B Bis, fourth paragraph, of the Federal Tax Code and, once resolved, the jurisdictional body left the referred act without effect.

This Central Administration of Audit for Various Large Taxpayers, headquartered in Mexico City, attached to the General Administration of Large Taxpayers of the Tax Administration Service, based on what is established in Article 16, first paragraph, of the Political Constitution of the United Mexican States; Articles 17 and 31, fractions XI and XXXIV, of the Organic Law of the Federal Public Administration; Articles 1, 2, 3, 4, 7, fractions VII, XII and XVIII, and 8, fraction III, of the Law of the Tax Administration Service; Articles 1, 2, first paragraph, Section B, fraction V, subsection d), and second paragraph, 5, first paragraph, 11, fraction XVIII, 13, fractions I and VI, and 28, last paragraph, numeral 4, of the Internal Regulations of the Tax Administration Service; Article Third, fraction I, subsection a), of the Agreement by which various powers are delegated to the 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 relation to Article Eighth, fraction V, of the Agreement by which the powers of the public servants of the Tax Administration Service are delegated, published in the aforementioned informative medium on September 3, 2020, and Article Fifth, fractions V and VII, of the Agreement by which powers are delegated to the 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, seventh paragraph, of the Federal Tax Code, informs the following:

That, at the time, the taxpayer was notified of a presumption notice of improper transmission of the right to reduce fiscal losses, in accordance with the first and fourth paragraphs of Article 69-B Bis of the Federal Tax Code.

Following the procedure provided for in the aforementioned Article 69-B Bis of the Federal Tax Code and, in terms of the seventh paragraph of the aforementioned article, the aforementioned taxpayer was notified of the definitive resolution by which it was indicated that they did not disprove the facts that led the authority to notify them as indicated below:

Notification of the DEFINITIVE RESOLUTION:

Tax ID (R.F.C.)
Name, denomination or corporate name of the Taxpayer Number and date of definitive resolution Issuing authority of the definitive resolution Notification via Tax Box to the taxpayer Notification date Date on which the notification took effect

OAN151230HWA
OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.
900-04-03-00-00-2023-251 dated May 17, 2023
Administration of Audit for Various Large Taxpayers " 3 " May 17, 2023 May 18, 2023

Additional Data:

Tax ID (R.F.C.)
Name, denomination or corporate name of the Taxpayer Fiscal Address Predominant Activity Reason for the Procedure

OAN151230HWA
OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.
Bosque de Cidros Street, No. 173, Interior 3rd Floor, Bosques de las Lomas Neighborhood, Cuajimalpa de Morelos Municipality, Mexico City, C.P. 05120. Construction of highways, freeways, dirt roads, bridges, overpasses, and airstrips. Improper transmission of fiscal losses resulting from spin-off.

For the above reason, the name of the taxpayer to whom the aforementioned resolution was notified was added to the list referred to in the ninth paragraph of Article 69-B Bis of the Federal Tax Code, which was published in the Official Gazette of the Federation, as indicated below:

Tax ID (R.F.C.)
Name of the Taxpayer
Number and date of office containing the definitive resolution SAT definitive publication page DOF definitive publication

OAN151230HWA
OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.
900-04-00-00-00-2024-80 of January 25, 2024
25/01/2024
05/07/2024

Disagreeing with the definitive resolution notice, Operadora Autopistas Nacionales Equivent, S.A. de C.V. filed a legal remedy, which concluded with the following ruling:

Tax ID (R.F.C.)
Name of the Taxpayer
Legal Remedy
Date of the Resolution or Final Ruling
Authority that Resolved
Sense and/or Effect of the Resolution or Final Ruling

OAN151230HWA
OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.
Amparo en Revisión R.A. 550/2023
12/09/2025
Thirteenth Collegiate Administrative Tribunal of the First Circuit The taxpayer is granted protection and protection so that the Authority leaves unsubstantiated the resolution contained in office 900-04-03-00-00-251, of May 17, 2023.

In view of the foregoing, it is communicated that, as a consequence of the legal remedy indicated in the preceding paragraph and in strict compliance with what was resolved by the Thirteenth Collegiate Administrative Tribunal of the First Circuit, the resolution contained in office number 900-04-03-00-00-2023-251 dated May 17, 2023, derived from the procedure of Article 69-B Bis of the Federal Tax Code followed against Operadora Autopistas Nacionales Equivent, S.A. de C.V., is left unsubstantiated.

Respectfully,

Mexico City, March 12, 2026. - Central Administrator of Audit for Various Large Taxpayers, L.C. Alejandro Alcides Villalta Ramírez. - Rubric.

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