Regulatory Alerts2023-10-20 | DOF 5706072Added
Official Letter 500-05-2023-15961 listing taxpayers who challenged the Article 69-B presumption letter (Federal Fiscal Code, in force until July 24, 2018) or its resolution, where the authority rendered the act insubsistent.
This official letter communicates a list of 29 taxpayers who filed legal defenses against presumption letters or definitive resolutions under Article 69-B of the Federal Fiscal Code (in force until July 24, 2018). Jurisdictional or administrative authorities subsequently declared the contested acts insubsistent, as detailed in the included tables showing nullity judgments and resolution dates. The document specifies the notification details, fiscal addresses, and publication data associated with each taxpayer's case.
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Official Gazette of the Federation: 20/10/2023
OFFICIAL LETTER 500-05-2023-15961 through which a list of taxpayers is communicated 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, in force until
At the margin a seal with the National Shield, which says: United Mexican States.- TREASURY.- Secretariat of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Tax Audit.- Central Administration of Strategic Oversight.
Official Letter: 500-05-2023-15961
Subject: A list of taxpayers is communicated 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 (FFC), in force until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article and once resolved, the jurisdictional or administrative body rendered the referred act insubsistent.
This 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, subsection 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, in force 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 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, in force from January 01, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, fraction I, subsection 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, in force 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 first and second 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 Official Gazette of the Federation on June 25, 2018 and Article Thirteenth, fraction IV, of the Miscellaneous Tax Resolution for 2023, published in the Official Gazette of the Federation on December 27, 2022, communicates the following:
That to the taxpayers listed below, at the time, they were notified a Presumption Letter of non-existence of operations covered by certain tax receipts that they issued, this in accordance with the first and second paragraphs of Article 69-B of the Federal Fiscal Code in force until July 24, 2018, in relation to Article 69 of its Regulations.
Following the procedure provided for in the aforementioned Article 69-B of the Federal Fiscal Code in force until July 24, 2018, and in terms of the third paragraph of the aforementioned article, the reference taxpayers were notified the definitive resolution as indicated below:
Notification to the taxpayer of the letter of the DEFINITIVE RESOLUTION.
| No. | R.F.C. | Name, denomination or corporate name of the Taxpayer | Notification Method to the Taxpayer | Number and date of definitive resolution letter | Tax Mailbox Date Notified | Tax Mailbox Date Effective | Authority Notice Boards Date Posted | Authority Notice Boards Date Effective | Personal Notification Date | Personal Notification Date Effective |
|---|---|---|---|---|---|---|---|---|---|---|
| 1 | ACO040216V89 | ADV CORP, S.A. DE C.V. | 500-43-00-06-00-2018-5671 dated September 06, 2018 | September 12, 2018 | September 13, 2018 | |||||
| 2 | AAS120821ID9 | ARGENTA ASESORES, S.C. | 500-50-00-06-01-2017-20258 dated December 14, 2017 | July 13, 2018 | August 21, 2018 | |||||
| 3 | BTR1508194G3 | BEAUTY TRENDS, S.A. DE C.V. | 500-21-00-04-02-2022-1656 dated August 15, 2022 | August 19, 2022 | August 22, 2022 | |||||
| 4 | CIE1002042L8 | CENTRO DE INNOVACION E INVESTIGACION DE SISTEMAS PARA LA EDIFICACION Y ENERGIAS RENOVABLES, S.A.P.I. DE C.V. | 500-47-00-06-00-2019-007223 dated September 26, 2019 | September 26, 2019 | September 27, 2019 | |||||
| 5 | CGI1311087L0 | COMERCIALIZADORA GIHESA, S.A. DE C.V. | 500-04-00-00-00-2018-28044 dated September 24, 2018 | October 01, 2018 | October 02, 2018 | |||||
| 6 | CJU121105B24 | CONSTRUCTORA JUDBET, S.A. DE C.V. | 500-04-00-00-00-2019-7455 dated February 11, 2019 | February 25, 2019 | March 21, 2019 | |||||
| 7 | DPR120412MN9 | DESARROLLO PROSIN, S.A. DE C.V. | 500-51-00-04-02-2017-06796 dated March 30, 2017 | April 04, 2017 | April 05, 2017 | |||||
| 8 | FAB950909B40 | FABARO, S.A. DE C.V. | 500-39-00-05-01-2019-9947 dated September 03, 2019 | September 11, 2019 | September 12, 2019 | |||||
| 9 | GOAF6811174Y9 | GÓMEZ ARREOLA FERNANDO | 500-09-00-07-01-2017-04778 dated October 25, 2017 | November 06, 2017 | November 30, 2017 | |||||
| 10 | GBE140219Q88 | GRUPO BELGIUN, S.A. DE C.V. | 500-28-00-04-00-2018-07170 dated November 08, 2018 | November 13, 2018 | November 14, 2018 | |||||
| 11 | ICA1008264A4 | INDUSTRIAS CAPAYU, S.A. DE C.V. | 500-04-00-00-00-2018-20960 dated July 30, 2018 | August 02, 2018 | August 03, 2018 | |||||
| 12 | IIY111111IG5 | INYSDEM INGENIERÍA Y SOPORTE DE EQUIPO MÉDICO, S.A. DE C.V. | 500-35-00-06-01-2017-23207 dated November 27, 2017 | December 08, 2017 | January 16, 2018 | |||||
| 13 | JLF0601137S3 | JOSÉ LUIS FRANCISCO PÉREZ MESEGUER E HIJOS, S.C. | 500-57-00-05-01-2018-003205 dated June 14, 2018 | June 22, 2018 | July 31, 2018 | |||||
| 14 | KEC1210224N8 | KECHOLI, S.A. DE C.V. | 500-50-00-06-01-2018-11353 dated October 04, 2018 | October 18, 2018 | October 19, 2018 | |||||
| 15 | MADE500722TC5 | MARTÍNEZ DORANTES MARÍA ELENA | 500-04-00-00-00-2018-10625 dated April 23, 2018 | May 08, 2018 | May 31, 2018 | |||||
| 16 | MED140827DH3 | MEDRAMEX, S.A. DE C.V. | 500-10-00-07-01-2018-28217 dated June 18, 2018 | June 27, 2018 | June 28, 2018 | |||||
| 17 | PPC101202C21 | PCS PROVEEDORA COMERCIAL Y DE SERVICIOS DE LA BAJA, S.A. DE C.V. | 500-13-00-02-00-2016-5134 dated November 10, 2016 | November 18, 2016 | November 22, 2016 | |||||
| 18 | PRC1501309A4 | PRODUCTORES RURALES DE CHIAPAS, S.P.R. DE R.L. | 500-70-00-07-02-2018-07392 dated August 02, 2018 | August 16, 2018 | September 10, 2018 | |||||
| 19 | PNS090707L42 | PROYECCIÓN DE NEGOCIOS SIGLO XXI QCK, S.A. DE C.V. | 500-45-00-04-01-2018-19105 dated October 03, 2018 | October 16, 2018 | October 17, 2018 | |||||
| 20 | RAOR681225AJ2 | RAMÍREZ OCHOA ROSA VELIA | 500-47-00-07-02-2016-022287 dated November 04, 2016 | November 08, 2016 | December 02, 2016 | |||||
| 21 | ROAY860519NC0 | ROMERO ACEVEDO YURIDIA YASMÍN TONANSI | 500-12-00-04-02-2017-11849 dated December 05, 2017 | December 06, 2017 | December 07, 2017 | |||||
| 22 | SAS1506091K4 | SAMPERIO ASESORES, S.A. DE C.V. | 500-57-00-04-01-2018-001667 dated April 20, 2018 | April 24, 2018 | April 25, 2018 | |||||
| 23 | SIR110204RX3 | SERVICIOS INTEGRALES RIOMART, S.A. DE C.V. | 500-71-2018-70835 dated November 20, 2018 | November 23, 2018 | December 18, 2018 | |||||
| 24 | SIB120622MC3 | SOLUCIONES INTELIGENTES DE LA BAJA, S.A. DE C.V. | 500-12-00-04-01-2018-00776 dated January 12, 2018 | January 18, 2018 | January 19, 2018 | |||||
| 25 | SCA120105UL7 | SUMOSCK CORPORATIVO ADMINISTRATIVO, S.A. DE C.V. | 500-04-00-00-00-2018-10496 dated June 25, 2018 | August 03, 2018 | August 06, 2018 | |||||
| 26 | SRE0904085K3 | SUSTENTO REAL EMPRESARIAL, S.A. DE C.V. | 500-05-2015-18319 dated June 17, 2015 | July 22, 2015 | July 23, 2015 | |||||
| 27 | TSE121212TN3 | TIDE SOLUCIONES EMPRESARIALES, S.A. DE C.V. | 500-44-00-03-00-2018-01311 dated February 06, 2018 | March 22, 2018 | March 23, 2018 | |||||
| 28 | TAS120524TPA | TRANSPORTES ASIA, S.A. DE C.V. | 500-04-00-00-00-2016-13533 dated April 20, 2016 | May 12, 2016 | June 06, 2016 | |||||
| 29 | VPI090106S41 | VIVA DE LA PROPIEDAD INTELECTUAL, S.A. DE C.V. | 500-09-00-06-01-2017-02872 dated June 21, 2017 | July 07, 2017 | July 10, 2017 |
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 | ACO040216V89 | ADV CORP, S.A. DE C.V. | SAN PEDRO GARZA GARCÍA, NUEVO LEÓN | COMPUTER CONSULTING SERVICES. | Absence of assets<br>Absence of personnel |
| 2 | AAS120821ID9 | ARGENTA ASESORES, S.C. | GUADALAJARA JALISCO | OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES | Absence of assets<br>Absence of personnel |
| 3 | BTR1508194G3 | BEAUTY TRENDS, S.A. DE C.V. | CHIHUAHUA, CHIHUAHUA | OTHER FINISHING WORKS IN BUILDINGS. | Absence of assets,<br>Absence of personnel,<br>Lack of infrastructure |
| 4 | CIE1002042L8 | CENTRO DE INNOVACION E INVESTIGACION DE SISTEMAS PARA LA EDIFICACION Y ENERGIAS RENOVABLES, S.A.P.I. DE C.V. | EL MARQUÉS, QUERÉTARO | RESEARCH AND DEVELOPMENT SERVICES IN PHYSICAL SCIENCES OF LIFE AND ENGINEERING PROVIDED BY THE PRIVATE SECTOR. | Absence of assets<br>Absence of personnel |
| 5 | CGI1311087L0 | COMERCIALIZADORA GIHESA, S.A. DE C.V. | ZAPOPAN, JALISCO | COMPUTER CONSULTING SERVICES AND MARKET RESEARCH AND PUBLIC OPINION POLL SERVICES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 6 | CJU121105B24 | CONSTRUCTORA JUDBET, S.A. DE C.V. | ZUMPANGO DEL RÍO, GUERRERO | CONSTRUCTION OF WORKS FOR THE TREATMENT, DISTRIBUTION AND SUPPLY OF WATER AND DRAINAGE, OTHER CIVIL ENGINEERING OR HEAVY WORKS, CONSTRUCTION OF URBANIZATION WORKS AND CONSTRUCTION OF AGRICULTURAL IRRIGATION SYSTEMS. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 7 | DPR120412MN9 | DESARROLLO PROSIN, S.A. DE C.V. | BENITO JUAREZ, CIUDAD DE MÉXICO | ADMINISTRATION CONSULTING SERVICES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 8 | FAB950909B40 | FABARO, S.A. DE C.V., | TAXCO DE ALARCÓN, GUERRERO | RETAIL TRADE OF WATCHES, FINE JEWELRY AND DECORATIVE ARTICLES OF PRECIOUS MATERIALS. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 9 | GOAF6811174Y9 | GÓMEZ ARREOLA FERNANDO | PUERTO PEÑASCO, SONORA. | PRINTING OF CONTINUOUS FORMS AND OTHER PRINTED MATERIALS. | Absence of assets<br>Absence of personnel<br>Lack of infrastructure |
| 10 | GBE140219Q88 | GRUPO BELGIUN, S.A. DE C.V. | IGUALA DE LA INDEPENDENCIA, GUERRERO | CONSTRUCTION OF INDUSTRIAL SHIPS AND PLANTS. | Absence of assets<br>Absence of personnel |
| 11 | ICA1008264A4 | INDUSTRIAS CAPAYU, S.A. DE C.V. | NAUCALPAN DE JUÁREZ, ESTADO DE MÉXICO | OTHER WHOLESALE TRADE INTERMEDIARIES. | Absence of assets<br>Absence of personnel<br>Lack of infrastructure |
| 12 | IIY111111IG5 | INYSDEM INGENIERÍA Y SOPORTE DE EQUIPO MÉDICO, S.A. DE C.V. | TOLUCA, ESTADO DE MÉXICO | OTHER WHOLESALE TRADE INTERMEDIARIES. | Absence of assets<br>Absence of personnel |
| 13 | JLF0601137S3 | JOSÉ LUIS FRANCISCO PÉREZ MESEGUER E HIJOS, S.C. | VILLAHERMOSA, CENTRO, TABASCO | COMPUTER CONSULTING SERVICES. | Absence of assets.<br>Absence of personnel.<br>Lack of infrastructure |
| 14 | KEC1210224N8 | KECHOLI, S.A. DE C.V. | AZCAPOTZALCO, CIUDAD DE MÉXICO | ADVERTISING AGENCIES. | Absence of assets<br>Absence of personnel<br>Without material capacity |
| 15 | MADE500722TC5 | MARTÍNEZ DORANTES MARÍA ELENA | TAXCO DE ALARCÓN, GUERRERO | GOLDSMITHING AND JEWELRY OF METALS AND PRECIOUS STONES OTHER THAN GOLD, AND WHOLESALE TRADE OF JEWELRY, GOLDSMITHING, ARTISTIC OR ORNAMENTAL PIECES OF GOLD. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 16 | MED140827DH3 | MEDRAMEX, S.A. DE C.V. | GUADALAJARA, JALISCO | LABOR ADVISORY SERVICES AND ADMINISTRATIVE AND LEGAL CONSULTING. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 17 | PPC101202C21 | PCS PROVEEDORA COMERCIAL Y DE SERVICIOS DE LA BAJA, S.A. DE C.V. | MORELIA, MICHOACÁN DE OCAMPO | OTHER SERVICES RELATED TO ACCOUNTING. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 18 | PRC1501309A4 | PRODUCTORES RURALES DE CHIAPAS, S.P.R. DE R.L. | TONALÁ, CHIAPAS | BREEDING AND EXPLOITATION OF OTHER ANIMALS, SOWING, CULTIVATION AND HARVEST OF OTHER CROPS | Absence of personnel<br>Lack of infrastructure |
| 19 | PNS090707L42 | PROYECCIÓN DE NEGOCIOS SIGLO XXI QCK, S.A. DE C.V. | PUEBLA, PUEBLA | OTHER BUSINESS SUPPORT SERVICES | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 20 | RAOR681225AJ2 | RAMÍREZ OCHOA ROSA VELIA | CORREGIDORA, QUERÉTARO | WHOLESALE TRADE OF METALLIC WASTE. | Absence of assets.<br>Absence of personnel |
| 21 | ROAY860519NC0 | ROMERO ACEVEDO YURIDIA YASMÍN TONANSI | LA PAZ, BAJA CALIFORNIA SUR | MASONRY WORKS. | Absence of assets<br>Absence of personnel<br>Lack of infrastructure |
| 22 | SAS1506091K4 | SAMPERIO ASESORES, S.A. DE C.V. | OCUILTZAPOTLAN, TABASCO | ADMINISTRATION CONSULTING SERVICES, OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES, ACCOUNTING AND AUDITING SERVICES, AND OTHER WIRELESS TELECOMMUNICATIONS, EXCEPT SATELLITE SERVICES. | Absence of assets<br>Absence of personnel |
| 23 | SIR110204RX3 | SERVICIOS INTEGRALES RIOMART, S.A. DE C.V. | CUUHTÉMOC, CIUDAD DE MÉXICO | OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES. | Absence of assets,<br>Lack of infrastructure<br>Absence of personnel |
| 24 | SIB120622MC3 | SOLUCIONES INTELIGENTES DE LA BAJA, S.A. DE C.V. | SAN NICOLAS DE LOS GARZA, NUEVO LEÓN | OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 25 | SCA120105UL7 | SUMOSCK CORPORATIVO ADMINISTRATIVO, S.A. DE C.V. | AZCAPOTZALCO, CIUDAD DE MÉXICO | OTHER WHOLESALE TRADE INTERMEDIARIES. | Absence of assets<br>Absence of personnel<br>Lack of infrastructure |
| 26 | SRE0904085K3 | SUSTENTO REAL EMPRESARIAL, S.A. DE C.V. | PUEBLA, PUEBLA | ADMINISTRATION CONSULTING SERVICES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 27 | TSE121212TN3 | TIDE SOLUCIONES EMPRESARIALES, S.A. DE C.V. | OAXACA DE JUÁREZ, OAXACA | ADMINISTRATION CONSULTING SERVICES, ENGINEERING SERVICES, ARCHITECTURE SERVICES, LEGAL FIRMS AND ACCOUNTING AND AUDITING SERVICES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
| 28 | TAS120524TPA | TRANSPORTES ASIA, S.A. DE C.V. | IRAPUATO, GUANAJUATO | SCHOOL AND PERSONNEL TRANSPORT, OTHER FOREIGN GENERAL CARGO MOTOR TRANSPORT. | Absence of assets<br>Absence of personnel<br>Without material capacity |
| 29 | VPI090106S41 | VIVA DE LA PROPIEDAD INTELECTUAL, S.A. DE C.V. | TIJUANA, BAJA CALIFORNIA | SUPPORT SERVICES TO CARRY OUT LEGAL PROCEDURES. | Absence of assets<br>Absence of personnel<br>Without material capacity<br>Lack of infrastructure |
Therefore, the names or corporate name of the taxpayers to whom the aforementioned resolutions were notified were added to the list referred to in the third paragraph of Article 69-B of the Federal Fiscal Code in force until July 24, 2018, which was published in the Official Gazette of the Federation, as indicated below:
| No. | R.F.C. | Name, denomination or corporate name of the Taxpayer | Number and date of letter containing Definitive Global List | Publication Date in the Official Gazette of the Federation |
|---|---|---|---|---|
| 1 | ACO040216V89 | ADV CORP, S.A. DE C.V. | 500-05-2018-32782 dated December 12, 2018 | January 14, 2019 |
| 2 | AAS120821ID9 | ARGENTA ASESORES, S.C. | 500-05-2018-32756 dated November 28, 2018 | January 13, 2019 |
| 3 | BTR1508194G3 | BEAUTY TRENDS, S.A. DE C.V. | 500-05-2022-29380 dated December 14, 2022 | January 12, 2023 |
| 4 | CIE1002042L8 | CENTRO DE INNOVACION E INVESTIGACION DE SISTEMAS PARA LA EDIFICACION Y ENERGIAS RENOVABLES, S.A.P.I. DE C.V. | 500-05-2021-6936 dated April 26, 2021 | May 13, 2021 |
| 5 | CGI1311087L0 | COMERCIALIZADORA GIHESA, S.A. DE C.V. | 500-05-2018-32756 dated November 28, 2018 | January 13, 2019 |
| 6 | CJU121105B24 | CONSTRUCTORA JUDBET, S.A. DE C.V. | 500-05-2019-7412 dated May 15, 2019 | May 31, 2019 |
| 7 | DPR120412MN9 | DESARROLLO PROSIN, S.A. DE C.V. | 500-05-2017-16195 dated June 16, 2017 | June 30, 2017 |
| 8 | FAB950909B40 | FABARO, S.A. DE C.V., | 500-05-2020-3644 dated January 15, 2020 | February 18, 2020 |
| 9 | GOAF6811174Y9 | GÓMEZ ARREOLA FERNANDO | 500-05-2018-572 dated January 26, 2018 | February 26, 2018 |
| 10 | GBE140219Q88 | GRUPO BELGIUN, S.A. DE C.V. | 500-05-2019-7288 dated February 15, 2019 | March 28, 2019 |
| 11 | ICA1008264A4 | INDUSTRIAS CAPAYU, S.A. DE C.V. | 500-05-2018-27105 dated September 27, 2018 | October 23, 2018 |
| 12 | IIY111111IG5 | INYSDEM INGENIERÍA Y SOPORTE DE EQUIPO MÉDICO, S.A. DE C.V. | 500-05-2018-10859 dated April 27, 2018 | May 21, 2018 |
| 13 | JLF0601137S3 | JOSÉ LUIS FRANCISCO PÉREZ MESEGUER E HIJOS, S.C. | 500-05-2018-29779 dated October 17, 2018 | November 13, 2018 |
| 14 | KEC1210224N8 | KECHOLI, S.A. DE C.V. | 500-05-2019-7375 dated April 15, 2019 | May 14, 2019 |
| 15 | MADE500722TC5 | MARTÍNEZ DORANTES MARÍA ELENA | 500-05-2018-20841 dated July 12, 2018 | August 23, 2018 |
| 16 | MED140827DH3 | MEDRAMEX, S.A. DE C.V. | 500-05-2018-27059 dated September 19, 2018 | October 08, 2018 |
| 17 | PPC101202C21 | PCS PROVEEDORA COMERCIAL Y DE SERVICIOS DE LA BAJA, S.A. DE C.V. | This taxpayer was not published in the Definitive Global List, which is issued in terms of the third paragraph of Article 69-B, of the Federal Fiscal Code. | |
| 18 | PRC1501309A4 | PRODUCTORES RURALES DE CHIAPAS, S.P.R. DE R.L. | 500-05-2018-32751 dated November 22, 2018 | December 31, 2018 |
| 19 | PNS090707L42 | PROYECCIÓN DE NEGOCIOS SIGLO XXI QCK, S.A. DE C.V. | 500-05-2018-32783 dated December 13, 2018 | January 15, 2019 |
| 20 | RAOR681225AJ2 | RAMÍREZ OCHOA ROSA VELIA | 500-05-2017-2517 dated February 24, 2017 | March 14, 2017 |
| 21 | ROAY860519NC0 | ROMERO ACEVEDO YURIDIA YASMÍN TONANSI | 500-05-2018-14172 dated May 25, 2018 | June 28, 2018 |
| 22 | SAS1506091K4 | SAMPERIO ASESORES, S.A. DE C.V. | 500-05-2018-22861 dated August 27, 2018 | October 08, 2018 |
| 23 | SIR110204RX3 | SERVICIOS INTEGRALES RIOMART, S.A. DE C.V. | 500-05-2019-7322 dated March 15, 2019 | April 16, 2019 |
| 24 | SIB120622MC3 | SOLUCIONES INTELIGENTES DE LA BAJA, S.A. DE C.V. | 500-05-2018-13465 dated May 16, 2018 | May 31, 2018 |
| 25 | SCA120105UL7 | SUMOSCK CORPORATIVO ADMINISTRATIVO, S.A. DE C.V. | 500-05-2018-27105 dated September 27, 2018 | October 23, 2018 |
| 26 | SRE0904085K3 | SUSTENTO REAL EMPRESARIAL, S.A. DE C.V. | 500-05-2015-39249 dated December 16, 2015 | December 28, 2015 |
| 27 | TSE121212TN3 | TIDE SOLUCIONES EMPRESARIALES, S.A. DE C.V. | 500-05-2018-13465 dated May 16, 2018 | May 31, 2018 |
| 28 | TAS120524TPA | TRANSPORTES ASIA, S.A. DE C.V. | 500-05-2016-27146 dated August 16, 2016 | September 01, 2016 |
| 29 | VPI090106S41 | VIVA DE LA PROPIEDAD INTELECTUAL, S.A. DE C.V. | 500-05-2017-32168 dated September 26, 2017 | October 26, 2017 |
Dissatisfied with the individual presumption letter or definitive resolution letter, they filed means of defense which concluded with the following resolution or judgment:
| No. | R.F.C. | Name, denomination or corporate name of the Taxpayer | Defense Method | Resolution or Final Judgment Date | Authority that Resolved | Effect and/or outcome of the final resolution or judgment |
|---|---|---|---|---|---|---|
| 1 | ACO040216V89 | ADV CORP, S.A. DE C.V. | Nullity Trial 6/19-06-02-2 | October 01, 2021 | Second Regional Chamber of the Northeast, of the Federal Court of Administrative Justice | Nullity of the resolution contained in official letter number 500-43-00-06-00-2018-5671 dated September 06, 2018 issued by the Decentralized Administration of Fiscal Audit of Nuevo León "3" is declared. |
| 2 | AAS120821ID9 | ARGENTA ASESORES, S.C. | Nullity Trial 2048/22-07-03-8-OT | January 13, 2023 | Third Regional Chamber of the West, of the Federal Court of Administrative Justice. | Plain and simple nullity of the challenged resolutions is declared, consisting of official letter 500-50-00-06-01-2016-21670 dated December 09, 2019 and 500-50-00-06-01-2017-020258 dated December 14, 2017, issued by the Decentralized Administration of Fiscal Audit of San Luis Potosí "1". |
| 3 | BTR1508194G3 | BEAUTY TRENDS, S.A. DE C.V. | Nullity Trial 3296/22-04-01-9-OT | June 01, 2023 | North-Central I Regional Chamber, of the Federal Court of Administrative Justice | Plain and simple nullity of the challenged resolution is declared, consisting of official letter number 500-21-00-04-02-2022-1656 dated August 15, 2022 issued by the Decentralized Administration of Fiscal Audit of Chihuahua "1". |
| 4 | CIE1002042L8 | CENTRO DE INNOVACION E INVESTIGACION DE SISTEMAS PARA LA EDIFICACION Y ENERGIAS RENOVABLES, S.A.P.I. DE C.V. | Nullity Trial 20/661-24-01-02-02-OL | March 13, 2023 | Specialized Mixed Chamber for Online Trials and in Matters |
Environmental and of Regulation, of the Federal Court of Administrative Justice.
The nullity of the contested resolutions is declared, consisting of letters numbers 600- 47-01-01-0R-2020-0253 dated January 30, 2020, issued by the Decentralized Legal Administration of Querétaro " 1 " , through which the Revocation Appeal RRL20189010046 was resolved, as well as, the originally appealed number 500-47-00-06-00-2019-007223 of date September 26, 2019, issued by the Decentralized Tax Audit Administration of Querétaro " 1 " .
| No. | RFC | Taxpayer Name | Legal Action & File | Date | Authority | Resolution |
|---|---|---|---|---|---|---|
| 5 | CGI1311087L0 | COMERCIALIZADORA GIHESA, S.A. DE C.V. | Revocation Appeal RRL2018011213 | November 30, 2020 | Decentralized Legal Administration of Jalisco " 3 " | The resolution contained in letter 500-04-00-00-00-2018-28044 dated September 24, 2018, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination is rendered without effect. |
| 6 | CJU121105B24 | CONSTRUCTORA JUDBET, S.A. DE C.V. | Nullity Trial 1497/19-14-01-1 | March 02, 2021 | Regional Chamber of the Pacific of the Federal Court of Administrative Justice | The nullity of the contested resolution is declared, consisting of letter 600-27-00-2019-3370 dated October 29, 2019, issued by the Decentralized Legal Administration of Guerrero " 1 " , through which revocation appeal number RRL2019008728 was resolved; as well as of the originally appealed, consisting of the resolution contained in letter number 500-04-00-00-00-2019- 7455 dated February 11, 2019, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination. |
| 7 | DPR120412MN9 | DESARROLLO PROSIN, S.A. DE C.V. | Nullity Trial 11087/17-17-11-2 | December 14, 2027 | Eleventh Regional Metropolitan Chamber, of the Federal Court of Administrative Justice | The plain and simple nullity of the resolution consisting of letter number 500-51-00-04-02- 2017-06796 dated March 30, 2017, issued by the Decentralized Tax Audit Administration of Sinaloa " 1 " is declared. |
| 8 | FAB950909B40 | FABARO, S.A. DE C.V., | Nullity Trial 1350/19-14-01-2 | October 20, 2020 | Regional Chamber of the Pacific, of the Federal Court of Administrative Justice | The plain and simple nullity of the contested resolution is declared, consisting of letter 500-39-00-05-01- 2019-09947 dated September 03, 2019, issued by the Decentralized Tax Audit Administration of Morelos " 1 " . |
| 9 | GOAF6811174Y9 | GÓMEZ ARREOLA FERNANDO | Nullity Trial 1602/21-02-01-2 | March 01, 2023 | Regional Chamber of the Northwest II, of the Federal Court of Administrative Justice | The nullity of the contested resolution is declared, consisting of letter number 500-09-00-07-01- 2017-04778 dated October 25, 2017, issued by the Decentralized Tax Audit Administration of Baja California " 1 " . |
| 10 | GBE140219Q88 | GRUPO BELGIUN, S.A. DE C.V. | Nullity Trial 5361/19-07-01-4 | October 15, 2021 | First Regional Chamber of the West, of the Federal Court of Administrative Justice | The plain and simple nullity of the contested resolution is declared, consisting of letter 500-28-00-04-00- 2018-07170 dated November 08, 2018, issued by the Decentralized Tax Audit Administration of Guerrero " 2 " . |
| 11 | ICA1008264A4 | INDUSTRIAS CAPAYU, S.A. DE C.V. | Nullity Trial 34/19-11-02-4 | November 15, 2019 | Second Regional Chamber of the North- East of the State of Mexico, of the Federal Court of Administrative Justice | The nullity of the contested resolution is declared, consisting of letter 600-36-07-43-2018-14053 dated November 08, 2018, issued by the Decentralized Legal Administration of Mexico " 2 " , through which the online revocation appeal number RRL2018008723 was resolved; as well as of the originally appealed, consisting of the resolution contained in letter number 500-04-00- 00-00-2018-20960 dated July 30, 2018, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination. |
| 12 | IIY111111IG5 | INYSDEM ENGINEERING AND SUPPORT OF MEDICAL EQUIPMENT, S.A. DE C.V. | Nullity Trial 18/2855-24-01-03- 03-OL | March 17, 2020 | Specialized Chamber in Online Trials, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared, consisting first of letter numbers 600-35-2018-5457 dated October 19, 2018, issued by the Decentralized Legal Administration of Mexico " 1 " , through which it resolved the online revocation appeal registered with number RRL2018006215, as well as of the originally appealed; consisting of letter number 500-35-00-06-01-2017-23207 dated November 27, 2017, issued by the Decentralized Tax Audit Administration of Mexico " 1 " . |
| 13 | JLF0601137S3 | JOSÉ LUIS FRANCISCO PÉREZ MESEGUER AND SONS, S.C. | Nullity Trial 988/19-26-01-6 | March 16, 2023 | Regional Chamber of Tabasco and Auxiliary, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared, consisting of letter number 600-57- 04-2019-1645 dated August 13, 2019, issued by the Decentralized Legal Administration of Tabasco " 1 " , through which Revocation Appeal RRL2019003375 was resolved, and the originally appealed, contained in letters numbers 500-57-00-05-01-2018-001276 dated March 09, 2018, and 500-57-00-05-01-2018-003205 dated June 14, 2018, issued by the Decentralized Tax Audit Administration of Tabasco " 1 " . |
| 14 | KEC1210224N8 | KECHOLI, S.A. DE C.V. | Nullity Trial 9130/20-17-02-4 | November 22, 2022 | Second Regional Metropolitan Chamber, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared consisting of letter number 500-50- 00-06-01-2018-11353 dated October 04, 2018, issued by the Decentralized Tax Audit Administration of San Luis Potosí " 1 " . |
| 15 | MADE500722TC5 | MARTÍNEZ DORANTES MARÍA ELENA | Nullity Trial 587/21-14-01-8 | March 15, 2022 | Regional Chamber of the Pacific and Auxiliary, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared consisting of letter number 500-04- 00-00-00-2018-10625 dated April 23, 2018, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination. |
| 16 | MED140827DH3 | MEDRAMEX, S.A. DE C.V. | Nullity Trial 258/20-07-01-8 | October 01, 2021 | First Regional Chamber of the West, of the Federal Court of Administrative Justice. | The nullity of the contested resolution is declared, consisting of letter number 500-10-00-07-01- 2018-28217 dated June 18, 2018, issued by the Decentralized Tax Audit Administration of Baja California " 2 " . |
| 17 | PPC101202C21 | PCS COMMERCIAL AND SERVICE PROVIDER OF THE BAJA, S.A. DE C.V. | Nullity Trial 536/17-03-01-11 | August 18, 2021 | First Regional Chamber of the Northwest III, of the Federal Court of Administrative Justice. | The nullity of the contested resolution is declared, consisting of letter 500-13-00-02-00-2016-5134 dated November 10, 2016, issued by the Decentralized Tax Audit Administration of Baja California Sur " 2 " , for the purpose that the tax authority issues a new resolution in which it determines that the plaintiff company is not located in the hypothesis contemplated in Article 69-B, third paragraph of the Federal Fiscal Code. |
| 18 | PRC1501309A4 | RURAL PRODUCERS OF CHIAPAS, S.P.R. DE R.L. | Nullity Trial 21/562-24-01-02- 05-OL | February 18, 2022 | Specialized Chamber in Online Trials, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared consisting of letter number 500-70- 00-07-02-2018-07392 dated August 02, 2018, issued by the Decentralized Tax Audit Administration of Zacatecas " 1 " . |
| 19 | PNS090707L42 | BUSINESS PROJECTION 21ST CENTURY QCK, S.A. DE C.V. | Nullity Trial 3257/18-12-02-9 | July 03, 2019 | Second Regional Chamber of the East, of the Federal Court of Administrative Justice | The plain and simple nullity of the contested letter 500-45-00-04-01-2018-19105 dated October 03, 2018, issued by the Decentralized Tax Audit Administration of Puebla " 1 " is declared. |
| 20 | RAOR681225AJ2 | RAMÍREZ OCHOA ROSA VELIA | Nullity Trial 1599/21-09-01-4 | March 25, 2022 | Regional Chamber of the Center II, of the Federal Court of Administrative Justice. | The nullity of the contested resolution is declared, consisting of letter 500-47-00-07-02-2016- 022287 dated November 04, 2016, issued by the Decentralized Tax Audit Administration of Querétaro " 1 " , for the purpose that said communication be replaced (notification of the letter through which the procedure contained in Article 69-B of the Federal Fiscal Code was initiated) and the plaintiff be given the opportunity to exercise their right to a hearing and due defense, and thus the authority in full exercise of its faculties, issue a new one that complies with the requirement of basis and reasoning. |
| 21 | ROAY860519NC0 | ROMERO ACEVEDO YURIDIA YASMÍN TONANSI | Nullity Trial 4196/18-03-01-3 | December 02, 2021 | Regional Chamber of the Northwest III, of the Federal Court of Administrative Justice | The nullity of the contested resolution is declared consisting of letter number 600-12-2018-000911 dated May 16, 2018, issued by the Decentralized Legal Administration of Baja California Sur " 1 " , in which the revocation appeal, number RRL2018000890 was resolved, as well as the originally appealed resolution consisting of that contained in letter 500-12-00-04-00-2017-11849 dated December 05, 2017, issued by the Decentralized Legal Administration of Baja California Sur " 1 " , |
| 22 | SAS1506091K4 | SAMPERIO ADVISORS, S.A. DE C.V. | Nullity Trial 505/18-26-01-1 | August 12, 2019 | Regional Chamber of Tabasco, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared, consisting of letter number 500-57- 00-04-01-2018-001667 dated April 20, 2018, issued by the Decentralized Tax Audit Administration of Tabasco " 1 " . |
| 23 | SIR110204RX3 | INTEGRAL SERVICES RIOMART, S.A. DE C.V. | Nullity Trial 15501/20-17-14-6 | May 31, 2022 | Fourteenth Regional Metropolitan Chamber, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested act is declared consisting of letter number 500-71-2018-70835 of November 20, 2018, issued by the Decentralized Tax Audit Administration of the Federal District " 1 " . |
| 24 | SIB120622MC3 | INTELLIGENT SOLUTIONS OF THE BAJA, S.A. DE C.V. | Nullity Trial 1364/18-03-01-11 | September 23, 2021 | First Regional Chamber of the Northwest III, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared, consisting of letter number 500-12- 00-04-01-2018-00776 dated January 12, 2018, issued by the Decentralized Tax Audit Administration of Baja California Sur " 1 " . |
| 25 | SCA120105UL7 | SUMOSCK CORPORATE ADMINISTRATIVE, S.A. DE C.V. | Nullity Trial 13673/20-17-06-8 | June 14, 2021 | Sixth Regional Metropolitan Chamber, of the Federal Court of Administrative Justice. | The plain and simple nullity of the resolution is declared consisting of letter number 500-04-00-00-00- 2018-10496 dated June 25, 2018, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination of the Tax Administration Service. |
| 26 | SRE0904085K3 | SUSTENTO REAL EMPRESARIAL, S.A. DE C.V. | Nullity Trial 815/16-12-01-3-OT | June 02, 2017 | First Regional Chamber of the East, of the Federal Court of Administrative Justice | The nullity of the contested resolution is declared, consisting of letter 600-46-00-00-00-2015-0066 dated November 26, 2015, issued by the Decentralized Legal Administration of Puebla " 2 " , through which Revocation Appeal number RR92/2015 was resolved; as well as of the originally appealed, consisting of the resolution contained in letter number 500-05-2015-18319 dated June 17, 2015, issued by the Central Strategic Audit Administration. |
| 27 | TSE121212TN3 | TIDE BUSINESS SOLUTIONS, S.A. DE C.V. | Nullity Trial 3313/18-15-01-7 | December 02, 2019 | Regional Chamber of the Southeast, of the Federal Court of Administrative Justice. | The plain and simple nullity of the contested resolution is declared consisting of letter number 600-44- 00-00-00-2018-3707 dated August 24, 2018, issued by the Decentralized Legal Administration of Oaxaca " 1 " , through which Revocation Appeal RRL2018004361 was resolved and the originally appealed, consisting of that contained in letter number 500-44-00-03-00-2018-01311 dated February 06, 2018, issued by the Decentralized Tax Audit Administration of Oaxaca " 1 " . |
| 28 | TAS120524TPA | TRANSPORTES ASIA, S.A. DE C.V. | Nullity Trial 1464/17-10-01-2- OT | January 28, 2019 | Regional Chamber of the Center III, of the Federal Court of Administrative Justice. | The nullity of the contested resolution is declared, consisting of letter number 500-04-00-00-00- 2016-13533 dated April 20, 2016, issued by the Central Administration of Verification and Evaluation of Federal Entities in Fiscal Coordination. |
| 29 | VPI090106S41 | VIVA DE LA PROPIEDAD INTELECTUAL, S.A. DE C.V. | Nullity Trial 3315/18-01-02-6 | August 11, 2022 | Second Regional Chamber of the Northwest I, of the Federal Court of Administrative Justice. | The nullity of the contested resolution is declared, consisting of letter number 500-09-00-06-01- 2017-02872 dated June 21, 2017, issued by the Decentralized Tax Audit Administration of Baja California " 1 " . |
In view of the foregoing, 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 in force until July 24, 2018 , followed with those taxpayers also, has been rendered without effect.
Finally it is informed that the fact that the taxpayers indicated above have obtained a favorable resolution against the presumption letters and/or definitive resolution, does not exempt them from the responsibility they may have regarding other tax vouchers that they have issued without having the assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or produce, market or deliver the goods that supported such vouchers, therefore, the faculties of the tax authority are left safeguarded.
Sincerely.
Mexico City, on August 09, 2023. - In substitution for absence of the Central Administrator of Strategic Audit, of the Coordinator of Strategic Audit, of the Administrator of Strategic Audit " 1 " , " 2 " , " 3 " , " 4 " , " 5 " and " 6 " , based on articles 4, fourth paragraph, and 22, last paragraph, number 5 subsection h), of the Internal Regulations of the Tax Administration Service in force , signs: Strategic Audit Administrator " 7 " , L.C. Susana Herrera Maldonado .- Signature.
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