Office 500-05-2023-15593 Communicating the Definitive Global List under Article 69-B, Third Paragraph, of the Federal Fiscal Code Valid Until July 24, 2018

DOF: 08/08/2023

OFFICIAL LETTER 500-05-2023-15593 through which the definitive global list is communicated in terms of the third paragraph of Article 69-B of the Federal Fiscal Code valid until July 24, 2018

On the margin a seal with the National Shield, stating: United Mexican States.- FINANCE.- Secretariat of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Tax Audit.- Central Administration of Strategic Tax Enforcement.

Official Letter: 500-05-2023-15593

Subject:

The definitive global list is communicated in terms

of the third paragraph of Article 69-B of the Federal

Fiscal Code valid until July 24,

2018.

The Central Administration of Strategic Tax Enforcement, 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 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 of the Federation on June 12, 2003; 1, 2, first paragraphs, Section B, section III, subsection e), and second, 5, first paragraph, 13, section VI, 23, Section E, section I, in relation to article 22 first paragraphs,

section 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, valid from November 22, 2015, of

conformity with the provisions of the first paragraph of Article One Transitory of said Regulations and

reformed by Decree reforming and adding various provisions of the Internal Regulations of the Secretariat 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, valid from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Three, section I, subsection a), of the Agreement through which various attributes are delegated to the Public Servants of the Tax Administration Service, published in the Official Gazette of the Federation on June 23, 2016, valid 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, of the Federal Fiscal Code in force and 69-B, first, third and fourth paragraphs of the Federal Fiscal Code valid until July 24, 2018, in relation to the Second Transitory Article of the "DECREE reforming article 69-B of the Federal Fiscal Code", published in the Official Gazette of the Federation on June 25, 2018 and Twenty-Fourth Transitory Article, section I) of the Miscellaneous Fiscal Resolution for 2023, published in the Official Gazette of the Federation on December 27, 2022, notifies the following:

Derived from the exercise of the attributes and powers indicated in the first and second paragraphs of article 69-B of the Federal Fiscal Code valid until July 24, 2018, 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.

Upon detecting such situation, the tax authority in order to comply with article 69-B, second paragraph, of the Federal Fiscal Code valid until July 24, 2018, 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 bases 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 valid until July 24, 2018.

Now then, 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 of the same.

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 (DOF) in the terms specified in annex 1, sections B and C, of this official letter, which is an integral part of the same, the above in accordance with the precedence established in article 69, first paragraph of the Regulations of the Federal Fiscal Code in force, in correlation with article 135 of the Federal Fiscal Code.

Attending to the provisions of the second paragraph of article 69-B of the Federal Fiscal Code valid until July 24, 2018, 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 made statements and provided the evidence they considered pertinent to disprove the facts made known through said letters, warned that if the granted period elapsed without providing the documentation and information and/or that which was exhibited, once valued, did not disprove the facts indicated in the letters in question, proceedings would be carried out by said authorities in terms of the third paragraph of article 69-B of the Federal Fiscal Code valid until July 24, 2018, first to notify them of the definitive individual 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 valid until July 24, 2018.

Once the period indicated in the previous paragraph 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 valid until July 24, 2018, in exercise of the right provided 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 stated 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 accordingly and proceeded to the issuance of the definitive resolutions in which the reasons, motives and bases 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 third paragraph of article 69-B of the Federal Fiscal Code valid until July 24, 2018, in relation to the Second Transitory Article of the "DECREE reforming article 69-B of the Federal Fiscal Code", published in the Official Gazette of the Federation on June 25, 2018, states 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, valid until July 24, 2018, that has been initiated against them; therefore, with the purpose of giving full compliance to the Third Resolution contained in the cited definitive resolutions, this Central Administration of Strategic Tax Enforcement, 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 valid until July 24, 2018, for the reasons and bases 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 fiscal effect, as declared by the fourth paragraph of article 69-B of the Federal Fiscal Code valid until July 24, 2018; the above, since it is of public interest that the invoicing of non-existent operations be stopped, as well as that society knows who are those taxpayers that carry out this type of operations.

Sincerely,

Mexico City, June 29, 2023. - In substitution for the absence of the Central Administrator of Strategic Tax Enforcement, of the Coordinator of Strategic Tax Enforcement and of the Administrators of Strategic Tax Enforcement "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,

Signature:

Administrator of Strategic Tax Enforcement "7", L.C. Susana Herrera Maldonado.- Signature Mark.

Annex 1 of official letter number 500-05-2023-15593 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 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.

No.	R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Individual Presumption Letter	Issuing Authority of the Individual Presumption Letter	Notification Method to the Taxpayer: Notice Boards of the Authority (Date of Fixation, Effect Date)	Notification Method: Personal Notification (Date, Effect Date)	Notification Method: Tax Mailbox (Date, Effect Date)
1	CFI160331RC5	COMERCIAL FINIBUS, S.A. DE C.V.	500-52-00-04-00-2018-06523 dated June 20, 2018	Decentralized Administration of Federal Tax Audit of Sinaloa "2"	June 25, 2018	June 26, 2018
2	SPI0705255B4	SEGURIDAD PRIVADA, INTELIGENCIA CIBERNETICA, S.A. DE C.V.	500-05-2018-13420 dated May 03, 2018	Central Administration of Strategic Tax Enforcement	May 04, 2018	May 07, 2018

Section B.- Notification on the Internet Page of the Tax Administration Service

No.	R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Global Presumption Letter	Issuing Authority of the Global Presumption Letter	Date of Notification on the Internet Page of the Tax Administration Service	Date on which Notification Took Effect
1	CFI160331RC5	COMERCIAL FINIBUS, S.A. DE C.V.	500-05-2018-20880 dated August 02, 2018	Central Administration of Strategic Tax Enforcement	August 02, 2018	August 03, 2018
2	SPI0705255B4	SEGURIDAD PRIVADA, INTELIGENCIA CIBERNETICA, S.A. DE C.V.	500-05-2018-16632 dated June 01, 2018	Central Administration of Strategic Tax Enforcement	June 01, 2018	June 04, 2018

Section C.- Notification in the Official Gazette of the Federation.

No.	R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Global Presumption Letter	Issuing Authority of the Global Presumption Letter	Date of Notification in the Official Gazette of the Federation	Date on which Notification Took Effect
1	CFI160331RC5	COMERCIAL FINIBUS, S.A. DE C.V.	500-05-2018-20880 dated August 02, 2018	Central Administration of Strategic Tax Enforcement	August 27, 2018	August 28, 2018
2	SPI0705255B4	SEGURIDAD PRIVADA, INTELIGENCIA CIBERNETICA, S.A. DE C.V.	500-05-2018-16632 dated June 01, 2018	Central Administration of Strategic Tax Enforcement	June 25, 2018	June 26, 2018

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

No.	R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Number and Date of Definitive Resolution	Issuing Authority of the Definitive Resolution	Notification Method to the Taxpayer: Notice Boards of the Authority (Date of Fixation, Effect Date)	Notification Method: Personal Notification (Date, Effect Date)	Notification Method: Tax Mailbox (Date, Effect Date)
1	CFI160331RC5	COMERCIAL FINIBUS, S.A. DE C.V.	500-52-00-04-00-2019-06457 dated June 04, 2019	Decentralized Administration of Federal Tax Audit of Sinaloa "2"	June 07, 2019	June 10, 2019
2	SPI0705255B4	SEGURIDAD PRIVADA, INTELIGENCIA CIBERNETICA, S.A. DE C.V.	500-05-2023-4325 dated April 13, 2023	Central Administration of Strategic Tax Enforcement	April 19, 2023	April 20, 2023

Section E.- Additional Data of the Taxpayers.

No.	R.F.C.	Name, Denomination or Corporate Name of the Taxpayer	Fiscal Address	Preponderant Activity	Reason for Procedure
1	CFI160331RC5	COMERCIAL FINIBUS, S.A. DE C.V.	Mazatlán, Sinaloa	Accounting and auditing services	Absence of assets, Absence of personnel, Lack of infrastructure, Without material capacity
2	SPI0705255B4	SEGURIDAD PRIVADA, INTELIGENCIA CIBERNETICA, S.A. DE C.V.	Tlalpan, Mexico City	Protection and custody services through security system monitoring	Absence of assets, Absence of personnel, Without material capacity

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