Office 500-05-2023-15592 Through Which the Definitive Global List Is Communicated in Terms of Article 69-B, Fourth Paragraph of the Federal Fiscal Code

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OGF: 08/08/2023

OFFICIAL LETTER 500-05-2023-15592 through which the definitive global list is communicated in terms of Article 69-B, fourth paragraph of the Federal Fiscal Code

In the margin a seal with the National Shield, which says: United Mexican States.- FINANCE.- Ministry of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Tax Audit.- Central Administration of Strategic Oversight.

Official Letter: 500-05-2023-15592

Subject:

The definitive global list is communicated in terms

of Article 69-B, fourth paragraph of the Federal Fiscal

Code.

The Central Administration of Strategic Oversight, attached to the General Administration of Federal Tax 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, Sections VII, XII and XVIII and 8, Section 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 of the Federation on June 12, 2003; 1, 2, paragraphs first, Section B, Fraction III, Item e), and second, 5, paragraph first, 13, Fraction VI, 23, Section E, Fraction I, in relation to Article 22 paragraphs first, 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 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 Customs Agency of Mexico are issued, published in the same official body on December 21, 2021, effective from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, Fraction I, Item a), of the Agreement through which various powers 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 accordance with the provisions of the First Transitory Article of said Agreement; as well as in Articles 33, last paragraph, 63, and 69-B paragraphs first, fourth and fifth of the Federal Fiscal Code, notifies the following:

Derived from the exercise of the powers and faculties indicated in Article 69-B, paragraphs first and second of the Federal Fiscal Code, the tax authorities cited in Annex 1 which is an integral part of this official letter, detected that the taxpayers indicated in said Annex 1 issued tax receipts without having the assets, personnel, infrastructure or material capacity to provide the services or produce, market or deliver the goods covered by such receipts.

Once such situation was detected, the tax authority, in order to comply with Article 69-B, second paragraph, of the Federal Fiscal Code, as well as numeral 69 of the Regulations of said Code, issued an individual presumption letter to each of the taxpayers mentioned in said Annex 1, and in said letter 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 Fiscal Code.

Now, the individual letters indicated in the preceding paragraph were notified to each taxpayer in the terms specified in Annex 1, Section A, of this official letter, which is an integral part thereof.

On the other hand, the global list of presumption was notified on the Internet page of the Tax Administration Service; and through publication in the Official Gazette of the Federation (OGF) in the terms specified in Annex 1, Sections B and C, of this official letter, which is an integral part thereof, the foregoing in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Fiscal Code in force, in relation to Article 135 of the Federal Fiscal Code.

Attending to the provisions of the second paragraph of Article 69-B of the Federal Fiscal Code, in the individual presumption letters the tax authorities granted each taxpayer a period of fifteen business days counted from the last of the notifications previously made, so that they could make statements and provide the evidence they considered pertinent to disprove the facts made known through said letters, warned that if upon expiration of the granted period they did not provide the documentation and information and/or that which they exhibited, once valued, did not disprove the facts indicated in the letters of the matter, proceeding would be taken by said authorities in terms of the fourth paragraph of Article 69-B of the Federal Fiscal Code, first to notify them of the individual definitive resolution, as well as the publication of their names, denominations or corporate names in the list of taxpayers who did not disprove the facts made known and therefore, would be definitively in the situation referred to in the first paragraph of said Article 69-B of the Federal Fiscal Code.

Once the period indicated in the previous paragraph had elapsed, and by virtue of the fact that those taxpayers during the period established in the second paragraph of Article 69-B of the Federal Fiscal Code, in exercise of the right provided for in said legal precept, presented, through the means indicated in the own individual resolutions, diverse information, documentation and arguments in order to disprove the facts made known in the individual letters indicated above, and said authorities proceeded to the admission and valuation of the same.

Derived from the valuation mentioned in the preceding paragraph, and by virtue of the fact that with the arguments manifested and evidence provided by those taxpayers the referred authorities considered that those taxpayers did not disprove the facts that were imputed to them in the individual presumption letters already indicated, the same resolved the pertinent and proceeded to the issuance of the definitive resolutions in which the reasons, motives and grounds were indicated for why they did not disprove said facts; resolutions that were duly notified in the terms indicated in the paragraphs preceding to each of the taxpayers indicated in Annex 1, Section D, of this official letter.

For the foregoing and, taking into account that the fourth paragraph of Article 69-B of the Federal Fiscal Code, indicates that in no case 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, furthermore the cited 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 Fiscal Code, that has been initiated against them; therefore, with the purpose of giving full compliance to the Third Resolution contained in said definitive resolutions, this Central Administration of Strategic Oversight, attached to the General Administration of Federal Tax Audit of the Tax Administration Service, in support of the tax authorities indicated in Annex 1 of the present, proceeds to add the names, denominations or corporate names of the taxpayers indicated in Annex 1 of this official letter, in the list of taxpayers who did not disprove the facts that were imputed to them and therefore, are definitively in the situation referred to in the first paragraph of said Article 69-B of the Federal Fiscal Code, for the reasons and grounds indicated in the definitive resolutions notified to each of them, 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, in order to consider, with general effects, that the tax receipts issued by said taxpayers do not produce nor produced any tax effect, as declared by the fifth paragraph of Article 69-B of the Federal Fiscal Code; the foregoing, since it is of public interest that the invoicing of non-existent operations be stopped, as well as that society knows who those taxpayers are that carry out this type of operations.

Sincerely,

Mexico City, June 29, 2023.- In substitution for absence of the Central Administrator of Strategic Oversight, of the Coordinator of Strategic Oversight and of the Administrators of Strategic Oversight " 1 ", " 2 ", " 3 ", " 4 ", " 5 " and " 6 "

based on Articles 4, fourth paragraph, and 22, last paragraph, numeral 5 Item h), of the Internal Regulations of the Tax Administration Service in force,

Signature: Administrator of Strategic Oversight " 7 ", L.C. Susana Herrera Maldonado .- Initials.

Annex 1 of official letter number 500-05-2023-15592 dated June 29, 2023, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT disprove the reason for which they were notified of the presumption letter, reason for which, the situation referred to in the first paragraph of Article 69-B of the Federal Fiscal Code was DEFINITIVELY updated.

Section A.- Notification of the PRESUMPTION LETTER according to the first and second paragraphs of Article 69-B of the Federal Fiscal 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 Letter	Issuing Authority of Individual Presumption Letter	Notice Board Date of Posting	Notice Board Date of Effect	Personal Notification Date	Personal Notification Date of Effect	Tax Mailbox Notification Date	Tax Mailbox Notification Date of Effect
1 ACO140827JS7	ALEG CONSULTORIA, S.A. DE C.V.	500-05-2022-20171 dated September 02, 2022	Central Administration of Strategic Oversight	September 07, 2022	September 08, 2022
2 PSD160407P1A	PRESTACION DE SERVICIOS DEMETRIA, S.A. DE C.V.	500-45-00-02-03-2018-22498 dated November 20, 2018	Decentralized Administration of Federal Tax Audit of Puebla "1"	November 27, 2018	November 28, 2018
3 RSE171114DC3	RENOV SERVICIOS, S.A. DE C.V.	500-05-2019-35985 dated October 31, 2019	Central Administration of Strategic Oversight	November 05, 2019	November 06, 2019

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 Letter	Issuing Authority of Global Presumption Letter	Notification Date on Internet Page of Tax Administration Service	Notification Effect Date
1 ACO140827JS7	ALEG CONSULTORIA, S.A. DE C.V.	500-05-2022-29221 dated October 03, 2022	Central Administration of Strategic Oversight	October 03, 2022	October 04, 2022
2 PSD160407P1A	PRESTACION DE SERVICIOS DEMETRIA, S.A. DE C.V.	500-05-2019-7255 dated February 05, 2019	Central Administration of Strategic Oversight	February 05, 2019	February 06, 2019
3 RSE171114DC3	RENOV SERVICIOS, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Oversight	December 02, 2019	December 03, 2019

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 Letter	Issuing Authority of Global Presumption Letter	Notification Date in the Official Gazette of the Federation	Notification Effect Date
1 ACO140827JS7	ALEG CONSULTORIA, S.A. DE C.V.	500-05-2022-29221 dated October 03, 2022	Central Administration of Strategic Oversight	October 31, 2022	November 01, 2022
2 PSD160407P1A	PRESTACION DE SERVICIOS DEMETRIA, S.A. DE C.V.	500-05-2019-7255 dated February 05, 2019	Central Administration of Strategic Oversight	March 14, 2019	March 15, 2019
3 RSE171114DC3	RENOV SERVICIOS, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Oversight	December 26, 2019	January 8, 2020

Section D.- Notification of the DEFINITIVE RESOLUTION letter according to the fourth paragraph of Article 69-B of the Federal Fiscal Code.

R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Definitive Resolution	Issuing Authority of Definitive Resolution	Notice Board Date of Posting	Notice Board Date of Effect	Personal Notification Date	Personal Notification Date of Effect	Tax Mailbox Notification Date	Tax Mailbox Notification Date of Effect
1 ACO140827JS7	ALEG CONSULTORIA, S.A. DE C.V.	500-05-2023-4157 dated March 03, 2023	Central Administration of Strategic Oversight	March 09, 2023	March 10, 2023
2 PSD160407P1A	PRESTACION DE SERVICIOS DEMETRIA, S.A. DE C.V.	500-45-00-07-01-2019-11584 dated May 31, 2019	Decentralized Administration of Federal Tax Audit of Puebla "1"	June 05, 2019	June 06, 2019
3 RSE171114DC3	RENOV SERVICIOS, S.A. DE C.V. // In compliance with the sentence dated June 02, 2021, issued by the Regional Chamber of the Northwest II of the Federal Court of Administrative Justice, within the Nullity Trial 1196/20-02-01-9.	500-05-2023-3946 dated February 09, 2023	Central Administration of Strategic Oversight	February 15, 2023	February 16, 2023

Section E.- Additional Data of the Taxpayers.

R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Fiscal Address	Preponderant Activity	Reason for Procedure
1 ACO140827JS7	ALEG CONSULTORIA, S.A. DE C.V.	Naucalpan de Juarez, State of Mexico	Consulting services in administration	Absence of assets, Absence of personnel, Without material capacity
2 PSD160407P1A	PRESTACION DE SERVICIOS DEMETRIA, S.A. DE C.V.	Puebla, Puebla	Consulting services in administration	Absence of assets, Absence of personnel, Lack of infrastructure, Without material capacity
3 RSE171114DC3	RENOV SERVICIOS, S.A. DE C.V.	Hermosillo, Sonora	Other professional, scientific and technical services	Absence of assets, Absence of personnel, Without material capacity

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