Regulatory Alerts2023-07-12 | DOF 5695335Added
Official Letter 500-05-2023-15538 through which the definitive global list is communicated in terms of the third paragraph of article 69-B of the Federal Fiscal Code in force until July 24, 2018
This document communicates the definitive global list of taxpayers who issued tax receipts without possessing the assets, personnel, infrastructure, or material capacity to support the operations, pursuant to the third paragraph of Article 69-B of the Federal Fiscal Code in force until July 24, 2018. The included taxpayers failed to refute the presumption within the granted 15 business day period, resulting in definitive resolutions that determine their tax receipts produce no tax effects. The list comprises nine taxpayers, including individuals and legal entities, whose names are published on the Tax Administration Service website and in the Federal Official Gazette as of July 12, 2023.
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Federal Official Gazette: 12/07/2023
OFFICIAL LETTER 500-05-2023-15538 through which the definitive global list is communicated in terms of the third paragraph of article 69-B of the Federal Fiscal Code in force until July 24, 2018
In 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: 500-05-2023-15538
Subject:
The definitive global list is communicated in terms
of the third paragraph of article 69-B of the Federal
Fiscal Code in force until July 24,
The 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 Federal Official Gazette on December 15, 1995, reformed by Decree published in the same Federal Official Gazette 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 Federal Official Gazette on August 24, 2015, in force from November 22, 2015, in accordance with the provisions of the First Transitory Article of said Regulations and reformed by Decree reforming and adding various provisions of the Internal Regulations of the Secretariat of Treasury 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, in force from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Third Article, section I, subsection a), of the Agreement by which various powers are delegated to the Public Servants of the Tax Administration Service, published in the Federal Official Gazette on June 23, 2016, in force 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 in force 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 Federal Official Gazette on June 25, 2018 and Twenty-Fourth Transitory Article, section II) of the Miscellaneous Tax Resolution for 2023, published in the Federal Official Gazette on December 27, 2022, communicates the following:
Derived from the exercise of the powers and faculties indicated in the first and second paragraphs of article 69-B of the Federal Fiscal Code in force 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.
Once such situation was detected, the aforementioned tax authorities, in order to comply with the second paragraph of article 69-B of the Federal Fiscal Code in force 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 in force 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 Federal Official Gazette (DOF) in the terms specified in annex 1, section 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 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 force 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 would make statements and provide the evidence they considered pertinent to refute the facts made known through the aforementioned letters, warned that if the granted period elapsed without providing the documentation and information and/or that which they exhibited, once valued, did not refute 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 in force until July 24, 2018, first to notify them of the definitive individual resolution, as well as the publication of their names, business names or corporate names in the list of taxpayers who did not refute the facts made known and therefore, would be definitively in the situation referred to in the first paragraph of the aforementioned article 69-B of the Federal Fiscal Code in force until July 24, 2018.
Once the period indicated in the previous paragraph elapsed, and by virtue of the fact that the taxpayers during the period established in the second paragraph of article 69-B of the Federal Fiscal Code in force until July 24, 2018, did not appear before the corresponding tax authority despite being duly notified and, therefore, did not present any documentation tending to refute the facts made known through the aforementioned individual letters, the warning was made effective and therefore the tax authorities proceeded to issue the definitive individual resolutions in which it was determined that by not having appeared before the authority they did not refute the facts imputed to them, and, therefore, that the hypothesis provided for in the first paragraph of this article 69-B of the Federal Fiscal Code in force until July 24, 2018 is definitively updated, this for the reasons exposed in said definitive resolutions.
It should be noted that the definitive resolutions indicated in the previous paragraph were duly notified in the terms indicated in the paragraphs preceding 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, in force until July 24, 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 aforementioned 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, in force until July 24, 2018 that has been initiated against them; therefore, with the purpose of fully complying with the Third Resolution contained in the aforementioned definitive resolutions, this Central Administration of Strategic Audit 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, business names or corporate names of the taxpayers indicated in Annex 1 of this official letter, in 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 of the Federal Fiscal Code in force 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 Federal Official Gazette, 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 fourth paragraph of article 69-B of the Federal Fiscal Code in force 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 those taxpayers are that carry out this type of operations.
Sincerely,
Mexico City, June 20, 2023. - In substitution for absence of the Central Administrator of Strategic Audit, of the Coordinator of Strategic Audit and of the Administrators of Strategic Audit " 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, Strategic Audit Administrator " 7 ", L.C. Susana Herrera Maldonado .- Rubric.
Annex 1 of official letter number 500-05-2023-15538 dated June 20, 2023, corresponding to taxpayers who did NOT provide arguments or evidence to refute 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.
| Federal Taxpayer Registry (R.F.C.) | Name, business name or corporate name of the Taxpayer | Number and date of individual presumption letter | Issuing Authority of the individual presumption letter | Notification Method to Taxpayer - Court Boards of the Authority - Date of posting in the Court Boards of the Tax Authority | Notification Method to Taxpayer - Court Boards of the Authority - Date notification took effect | Notification Method to Taxpayer - Personal Notification - Date of notification | Notification Method to Taxpayer - Personal Notification - Date notification took effect | Notification Method to Taxpayer - Tax Mailbox Notification - Date of notification | Notification Method to Taxpayer - Tax Mailbox Notification - Date notification took effect |
|---|---|---|---|---|---|---|---|---|---|
| 1 | CANC901221K61 | CABRERA NARANJO CINDY CAROLINA | 500-52-00-01-00-2017-05315 dated May 23, 2017 | Decentralized Administration of Tax Audit of Sinaloa "2" | June 12, 2017 | June 13, 2017 | |||
| 2 | CAUC6002213S7 | CARDENAS URIBE CARLOS JAVIER | 500-52-00-01-00-2017-05317 dated May 23, 2017 | Decentralized Administration of Tax Audit of Sinaloa "2" | June 12, 2017 | June 13, 2017 | |||
| 3 | CDN1412025P0 | CONSTRUCTORA DICA DEL NOROESTE, S. DE R.L. DE C.V. | 500-52-00-01-00-2017-07060 dated August 03, 2017 | Decentralized Administration of Tax Audit of Sinaloa "2" | August 09, 2017 | August 10, 2017 | |||
| 4 | CDR140311H93 | COMERCIALIZADORA DREMENS, S. DE R.L. DE C.V. // In compliance with the sentence dated May 02, 2019, issued by the Second Regional Chamber of the Northwest I, of the Federal Court of Administrative Justice, within the Nullity Trial 262/18-01-02-4. | 500-10-00-07-03-2017-37163 dated August 23, 2017 | Decentralized Administration of Tax Audit of Baja California "2" | April 08, 2020 | April 13, 2020 | |||
| 5 | COSG531117N11 | COVARRUBIAS SALAS GERMAN | 500-52-00-01-00-2017-07171 dated August 02, 2017 | Decentralized Administration of Tax Audit of Sinaloa "2" | December 07, 2017 | January 15, 2018 | |||
| 6 | CUCP890302UA7 | CRUZ CASTILLO PAUL ADRIAN | 500-66-00-03-01-2018-1363 dated January 16, 2018 | Decentralized Administration of Tax Audit of Veracruz "3" | April 09, 2018 | May 03, 2018 | |||
| 7 | GURO610322619 | GUEVARA RODRIGUEZ OCTAVIO | 500-52-00-01-00-2017-07847 dated August 02, 2017 | Decentralized Administration of Tax Audit of Sinaloa "2" | August 25, 2017 | September 19, 2017 | |||
| 8 | PAP1406249Y1 | PROYECTOS Y ACABADOS PRAGA, S.A. DE C.V. | 500-52-00-01-00-2018-07390 dated July 05, 2018 | Decentralized Administration of Tax Audit of Sinaloa "2" | July 13, 2018 | July 30, 2018 | |||
| 9 | PEHM740810JE9 | PEREZ HERNANDEZ MARTIN | 500-38-00-06-02-2018-9822 dated June 18, 2018 | Decentralized Administration of Tax Audit of Michoacán "2" | June 20, 2018 | July 13, 2018 |
Section B.- Notification on the Internet page of the Tax Administration Service
| Federal Taxpayer Registry (R.F.C.) | Name, business name 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 notification took effect |
|---|---|---|---|---|---|
| 1 | CANC901221K61 | CABRERA NARANJO CINDY CAROLINA | 500-05-2017-16234 dated June 30, 2017 | Central Administration of Strategic Audit | July 03, 2017 |
| 2 | CAUC6002213S7 | CARDENAS URIBE CARLOS JAVIER | 500-05-2017-16234 dated June 30, 2017 | Central Administration of Strategic Audit | July 03, 2017 |
| 3 | CDN1412025P0 | CONSTRUCTORA DICA DEL NOROESTE, S. DE R.L. DE C.V. | 500-05-2017-32098 dated August 29, 2017 | Central Administration of Strategic Audit | September 01, 2017 |
| 4 | CDR140311H93 | COMERCIALIZADORA DREMENS, S. DE R.L. DE C.V. | 500-05-2023-3960 dated January 04, 2023 | Central Administration of Strategic Audit | January 04, 2023 |
| 5 | COSG531117N11 | COVARRUBIAS SALAS GERMAN | 500-05-2018-16632 dated June 01, 2018 | Central Administration of Strategic Audit | June 01, 2018 |
| 6 | CUCP890302UA7 | CRUZ CASTILLO PAUL ADRIAN | 500-05-2018-16632 dated June 01, 2018 | Central Administration of Strategic Audit | June 01, 2018 |
| 7 | GURO610322619 | GUEVARA RODRIGUEZ OCTAVIO | 500-05-2017-38736 dated December 01, 2017 | Central Administration of Strategic Audit | December 01, 2017 |
| 8 | PAP1406249Y1 | PROYECTOS Y ACABADOS PRAGA, S.A. DE C.V. | 500-05-2018-27118 dated October 02, 2018 | Central Administration of Strategic Audit | October 02, 2018 |
| 9 | PEHM740810JE9 | PEREZ HERNANDEZ MARTIN | 500-05-2018-22880 dated September 04, 2018 | Central Administration of Strategic Audit | September 05, 2018 |
Section C.- Notification in the Federal Official Gazette.
| Federal Taxpayer Registry (R.F.C.) | Name, business name 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 Federal Official Gazette | Date notification took effect |
|---|---|---|---|---|---|
| 1 | CANC901221K61 | CABRERA NARANJO CINDY CAROLINA | 500-05-2017-16234 dated June 30, 2017 | Central Administration of Strategic Audit | July 13, 2017 |
| 2 | CAUC6002213S7 | CARDENAS URIBE CARLOS JAVIER | 500-05-2017-16234 dated June 30, 2017 | Central Administration of Strategic Audit | July 13, 2017 |
| 3 | CDN1412025P0 | CONSTRUCTORA DICA DEL NOROESTE, S. DE R.L. DE C.V. | 500-05-2017-32098 dated August 29, 2017 | Central Administration of Strategic Audit | September 19, 2017 |
| 4 | CDR140311H93 | COMERCIALIZADORA DREMENS, S. DE R.L. DE C.V. | 500-05-2023-3960 dated January 04, 2023 | Central Administration of Strategic Audit | February 07, 2023 |
| 5 | COSG531117N11 | COVARRUBIAS SALAS GERMAN | 500-05-2018-16632 dated June 01, 2018 | Central Administration of Strategic Audit | June 25, 2018 |
| 6 | CUCP890302UA7 | CRUZ CASTILLO PAUL ADRIAN | 500-05-2018-16632 dated June 01, 2018 | Central Administration of Strategic Audit | June 25, 2018 |
| 7 | GURO610322619 | GUEVARA RODRIGUEZ OCTAVIO | 500-05-2017-38736 dated December 01, 2017 | Central Administration of Strategic Audit | December 26, 2017 |
| 8 | PAP1406249Y1 | PROYECTOS Y ACABADOS PRAGA, S.A. DE C.V. | 500-05-2018-27118 dated October 02, 2018 | Central Administration of Strategic Audit | October 23, 2018 |
| 9 | PEHM740810JE9 | PEREZ HERNANDEZ MARTIN | 500-05-2018-22880 dated September 04, 2018 | Central Administration of Strategic Audit | October 05, 2018 |
Section D.- Notification of the DEFINITIVE RESOLUTION letter according to the third paragraph of article 69-B of the Federal Fiscal Code.
| Federal Taxpayer Registry (R.F.C.) | Name, business name or corporate name of the Taxpayer | Number and date of definitive resolution | Issuing Authority of the definitive resolution | Notification Method to Taxpayer - Court Boards of the Authority - Date of posting in the Court Boards of the Tax Authority | Notification Method to Taxpayer - Court Boards of the Authority - Date notification took effect | Notification Method to Taxpayer - Personal Notification - Date of notification | Notification Method to Taxpayer - Personal Notification - Date notification took effect | Notification Method to Taxpayer - Tax Mailbox Notification - Date of notification | Notification Method to Taxpayer - Tax Mailbox Notification - Date notification took effect |
|---|---|---|---|---|---|---|---|---|---|
| 1 | CANC901221K61 | CABRERA NARANJO CINDY CAROLINA | 500-52-00-01-00-2018-09926 dated September 03, 2018 | Decentralized Administration of Tax Audit of Sinaloa "2" | September 14, 2018 | September 17, 2018 | |||
| 2 | CAUC6002213S7 | CARDENAS URIBE CARLOS JAVIER | 500-52-00-01-00-2018-09927 dated September 03, 2018 | Decentralized Administration of Tax Audit of Sinaloa "2" | October 12, 2018 | November 07, 2018 | |||
| 3 | CDN1412025P0 | CONSTRUCTORA DICA DEL NOROESTE, S. DE R.L. DE C.V. | 500-52-00-01-00-2018-13318 dated November 13, 2018 | Decentralized Administration of Tax Audit of Sinaloa "2" | November 21, 2018 | November 22, 2018 | |||
| 4 | CDR140311H93 | COMERCIALIZADORA DREMENS, S. DE R.L. DE C.V. | 500-10-00-07-03-2023-10722 dated March 29, 2023 | Decentralized Administration of Tax Audit of Baja California "2" | April 04, 2023 | April 05, 2023 | |||
| 5 | COSG531117N11 | COVARRUBIAS SALAS GERMAN | 500-52-00-01-00-2020-01444 dated February 07, 2020 | Decentralized Administration of Tax Audit of Sinaloa "2" | November 24, 2020 | January 07, 2021 | |||
| 6 | CUCP890302UA7 | CRUZ CASTILLO PAUL ADRIAN | 500-66-00-03-02-2018-8865 dated October 16, 2018 | Decentralized Administration of Tax Audit of Veracruz "3" | November 09, 2018 | December 05, 2018 | |||
| 7 | GURO610322619 | GUEVARA RODRIGUEZ OCTAVIO | 500-52-00-01-00-2018-09398 dated August 27, 2018 | Decentralized Administration of Tax Audit of Sinaloa "2" | October 19, 2018 | November 14, 2018 | |||
| 8 | PAP1406249Y1 | PROYECTOS Y ACABADOS PRAGA, S.A. DE C.V. | 500-52-00-01-00-2019-16200 dated December 19, 2019 | Decentralized Administration of Tax Audit of Sinaloa "2" | January 16, 2020 | January 17, 2020 | |||
| 9 | PEHM740810JE9 | PEREZ HERNANDEZ MARTIN | 500-37-00-07-01-2021-28082 dated November 29, 2021 | Decentralized Administration of Tax Audit of Michoacán "1" | December 01, 2021 | December 13, 2021 |
Section E.- Additional data of the taxpayers.
| Federal Taxpayer Registry (R.F.C.) | Name, business name or corporate name of the Taxpayer | Tax Domicile | Preponderant Activity | Reason for Procedure |
|---|---|---|---|---|
| 1 | CANC901221K61 | CABRERA NARANJO CINDY CAROLINA | Escuínapa, Sinaloa | Individual with business and professional activity |
| 2 | CAUC6002213S7 | CARDENAS URIBE CARLOS JAVIER | Mazatlán, Sinaloa | Hydrosanitary and gas installations in constructions |
| 3 | CDN1412025P0 | CONSTRUCTORA DICA DEL NOROESTE, S. DE R.L. DE C.V. | Guadalajara, Jalisco | Administration and Supervision of Construction of Works for the treatment, distribution and supply of water, drainage and irrigation |
| 4 | CDR140311H93 | COMERCIALIZADORA DREMENS, S. DE R.L. DE C.V. | Tijuana, Baja California | Wholesale trade of clothing |
| 5 | COSG531117N11 | COVARRUBIAS SALAS GERMAN | La Paz, Baja California | Wholesale trade of metallic rights |
| 6 | CUCP890302UA7 | CRUZ CASTILLO PAUL ADRIAN | Cordoba, Veracruz | Hydrosanitary and gas installations in constructions |
| 7 | GURO610322619 | GUEVARA RODRIGUEZ OCTAVIO | Zapopan, Jalisco | Wholesale trade of metallic waste |
| 8 | PAP1406249Y1 | PROYECTOS Y ACABADOS PRAGA, S.A. DE C.V. | Escárcega, Campeche | Other Civil Engineering or heavy work Constructions |
personal, Lack of infrastructure, Without material capacity
9
PEHM740810JE9
PEREZ HERNANDEZ MARTIN
Uruapan, Michoacán de Ocampo
Other General cargo motor transport
Absence of assets, Absence of personnel
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