Office 500-05-2023-21522 Listing Taxpayers Who Challenged Presumption Letter Under Article 69-B of Federal Fiscal Code or Resolution and Where Jurisdictional or Administrative Body Rendered Act Without Effect

DOF: 01/12/2023

OFFICIAL LETTER 500-05-2023-21522 whereby a list is communicated of taxpayers who promoted some means of defense against the presumption letter referred to in the first paragraph of Article 69-B of the Federal Fiscal Code or against the resolution referred to in the fourth paragraph of the aforementioned article and once resolved the same the jurisdictional or administrative body rendered the referred act without effect.

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

Official Letter: 500-05-2023-21522

Subject: List of taxpayers is communicated who promoted some means of defense against the presumption letter referred to in the first paragraph of the Federal Fiscal Code (CFF) or against the resolution referred to in the fourth paragraph of the aforementioned article and once resolved the same the jurisdictional or administrative body rendered the referred act without effect.

This Central Administration of Strategic Audit, 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, paragraphs first, section B, fraction III, inciso 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 whereby various provisions of the Internal Regulations of the Secretariat of Treasury and Public Credit and of the Internal Regulations of the Tax Administration Service are reformed and added, and whereby the Internal Regulations of the National Customs Agency of Mexico are issued, published in the same official organ on December 21, 2021, effective from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, section I, inciso a), of the Agreement whereby 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, effective from July 23, 2016, in accordance with the provisions of the First Transitory Article of said Agreement; in articles 33, last paragraph, 63 and 69-B, paragraphs sixth of the Federal Fiscal Code, communicates the following:

That to the taxpayer listed below, at the time, was notified a Presumption Letter of non-existence of operations covered by certain tax receipts that it issued, this in accordance with the first and second paragraphs of article 69-B of the Federal Fiscal Code, in relation to article 69 of its Regulations.

Following the procedure provided for in article 69-B of the Federal Fiscal Code, and in terms of the fourth paragraph of the aforementioned precept, the reference taxpayer was notified the definitive resolution as indicated below:

Notification to the taxpayer of the letter of the DEFINITIVE RESOLUTION.

R.F.C.	Name, Designation or Corporate Name of the Taxpayer	Notification Method to the Taxpayer	Number and Date of Definitive Resolution Letter
		Tax Mailbox	Authority Bulletin Boards	Personal Notification
		Date Notified in Tax Mailbox	Date Notification Took Effect	Date Fixed on Authority Fiscal Bulletin Boards	Date Notification Took Effect	Date of Notification	Date Notification Took Effect
1	PAF130422DS7	P & F ADVISORS, S.C.	500-73-05-12-03-2021-7371 dated July 07, 2021	July 09, 2021	August 04, 2021

Additional Data of the Taxpayers.

R.F.C.	Name, Designation or Corporate Name of the Taxpayer	Fiscal Address	Preponderant Activity	Reason for Procedure
1	PAF130422DS7	P & F ADVISORS, S.C.	BENITO JUÁREZ, MEXICO CITY	BUSINESS ADMINISTRATION SERVICES	Absence of assets Absence of personnel Lack of infrastructure

For the foregoing, the name or corporate name of the taxpayer to whom the cited resolution was notified was added to the list referred to in the fourth paragraph of article 69-B of the Federal Fiscal Code, which was published in the Official Gazette of the Federation, as indicated below:

R.F.C.	Name, Designation or Corporate Name of the Taxpayer	Number and Date of Letter Containing Definitive Global List	Date of Publication in the Official Gazette of the Federation
1	PAF130422DS7	P & F ADVISORS, S.C.	500-05-2021-26102 dated October 15, 2021	November 04, 2021

Dissatisfied with the individual presumption letter or definitive resolution letter, filed means of defense from which the following resolution or sentence was concluded:

R.F.C.	Name, Designation or Corporate Name of the Taxpayer	Means of Defense	Date of Firm Resolution or Sentence	Authority that Resolved	Sense and/or Effect of Firm Resolution or Sentence
1	PAF130422DS7	P & F ADVISORS, S.C.	Nullity Trial 31068/21-17-02-2	July 14, 2022	Second Metropolitan Regional Chamber of the Federal Court of Administrative Justice	The plain and simple nullity of the challenged resolution is declared, consisting of letter number 500-73-05-12-03-2021-7371 dated July 07, 2021, issued by the Decentralized Administration of Federal Tax Audit of the Federal District "3".

By virtue of the foregoing, and in compliance with the resolution dated September 27, 2023, resulting from the Complaint filed by the plaintiff party in the administrative contentious trial with file number 31068/21-17-02-2, as well as, the definitive sentence dated July 14, 2022, pronounced in the records of the referred trial, by the Second Metropolitan Regional Chamber of the Federal Court of Administrative Justice; it is informed that, as a consequence of the means of defense indicated in the preceding paragraph, the procedure of article 69-B of the Federal Fiscal Code, followed to that taxpayer, has been rendered without effect.

Finally, it is informed that, the fact that the taxpayer before mentioned has obtained a favorable resolution against the presumption letter and/or definitive resolution, does not exempt it from the responsibility it may have regarding other tax receipts that it has issued without counting with the assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or produce, market or deliver the goods that covered such receipts, for which, the faculties of the tax authority are left safeguarded.

Sincerely.

Mexico City, at October 12, 2023 .- In substitution for absence of the Central Administrator of Strategic Audit, of the Coordinator of Strategic Audit, of the Strategic Audit Administrator " 1 ", " 2 ", " 3 ", " 4 ", " 5 " and " 6 ", based on articles 4, paragraph fourth, and 22, last paragraph, numeral 5 inciso h), of the Internal Regulations of the Tax Administration Service in force,

signature:

Strategic Audit Administrator " 7 ", L.C. Susana Herrera Maldonado .- Signature Mark.

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