Official Letter 500-05-2024-18415 Communicating the Definitive Global List under Article 69-B, Paragraph 4 of the Federal Tax Code

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DOF: 18/10/2024

OFFICIAL LETTER 500-05-2024-18415 communicating the definitive global list under Article 69-B, paragraph four of the Federal Tax Code

At the margin, a seal with the National Coat of Arms, which reads: United Mexican States.- TREASURY.- Ministry of Finance and Public Credit.

Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Taxation.

Official Letter: 500-05-2024-18415

Subject:

Communication of the definitive global list under Article 69-B, paragraph four of the Federal Tax Code.

The Central Administration of Strategic Taxation, attached to the General Administration of Federal Fiscal Audit of the Tax Administration Service, based on the provisions of Article 16, first paragraph, of the Political Constitution of the United Mexican States; Articles 1, 7, fractions VII, XII and XVIII and 8, fraction III of the Law of the Tax Administration Service, published in the Official Gazette of the Federation on December 15, 1995, amended by Decree published in the same Official Gazette on June 12, 2003; Articles 1, 2, first paragraph, section B, fraction III, subsection e), and second, 5, first paragraph, 13, fraction VI, 23, section E, fraction I, in relation to Article 22, first paragraph, 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 amended by Decree amending 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 Agency of Customs of Mexico are issued, published in the same official organ on December 21, 2021, effective from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Three, fraction I, subsection a), of the Agreement by 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 Articles 33, last paragraph, 63 and 69-B, first, fourth and fifth paragraphs of the Federal Tax Code, notifies the following:

As a result of the exercise of the powers and authorities indicated in Article 69-B, first and second paragraphs of the Federal Tax 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 fiscal receipts without having the assets, personnel, infrastructure or material capacity to provide the services or produce, commercialize or deliver the goods covered by such receipts.

Having detected such a situation, the tax authority, in order to comply with Article 69-B, second paragraph of the Federal Tax 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 Tax 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 of it.

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 it, the above in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax Code in force, in relation to Article 135 of the Federal Tax Code.

Attending to what is provided by the second paragraph of Article 69-B of the Federal Tax Code, in the individual presumption letters the tax authorities granted each taxpayer a period of fifteen business days counted from the last of the aforementioned notifications, to make the statements and provide the evidence they considered pertinent to disprove the facts disclosed through the aforementioned letters, warned that if after the granted period they did not provide the documentation and information and/or what they exhibited, once evaluated, did not disprove the facts indicated in the letters in question, it would proceed by said authorities, in terms of the fourth paragraph of Article 69-B of the Federal Tax Code, first to notify them the definitive individual resolution, as well as the publication of their names, denominations or trade names in the list of taxpayers who did not disprove the facts disclosed and therefore, would be in a definitive situation referred to in the first paragraph of said Article 69-B of the Federal Tax Code.

Once the period indicated in the previous paragraph has elapsed, and in view of the fact that those taxpayers during the period established in the second paragraph of Article 69-B of the Federal Tax Code, did not appear before the corresponding tax authority, despite being duly notified and, therefore, did not present any documentation tending to disprove the facts disclosed through the aforementioned individual letters, the warning became effective, and the tax authorities proceeded to issue the definitive individual resolutions in which it was determined that by not appearing before the authority they did not disprove the facts imputed to them, and, therefore, that the hypothesis provided for in the first paragraph of this Article 69-B of the Federal Tax Code is definitively updated, 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 above and, taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code indicates that under no circumstances will the list be published before the thirty business days following the notification of the resolution and that, to date, said period has elapsed since the notification of the resolution and, in addition, 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 Tax Code, which has been initiated against them; therefore, in order to fully comply with Resolutive Third contained in said definitive resolutions, this Central Administration of Strategic Taxation attached to the General Administration of Federal Fiscal Audit of the Tax Administration Service, in support of the tax authorities indicated in Annex 1 of this, proceeds to add the names, denominations or trade names of the taxpayers indicated in Annex 1 of this official letter, in the list of taxpayers who did not disprove the facts imputed to them and therefore, are in a definitive situation referred to in the first paragraph of said Article 69-B of the Federal Tax 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 fiscal receipts issued by said taxpayers do not produce nor produced any fiscal effect whatsoever, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the above, since it is in the public interest to stop the billing of non-existent operations, as well as for society to know who those taxpayers are who carry out this type of operations.

Respectfully.

Mexico City, August 16, 2024. - In substitution for the absence of the Central Administrator of Strategic Taxation, by the Coordinator of Strategic Taxation, by the Administrator of Strategic Taxation "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, signs:

C.P.

Nayeli Margarita Ramos Hernández, Administrator of Strategic Taxation "7".- Rubric.

Annex 1 of official letter number 500-05-2024-18415 dated August 16, 2024, corresponding to taxpayers who DID NOT provide arguments or evidence to disprove the reason for which they were notified of the presumption letter, definitively updating the situation referred to in the first paragraph of Article 69-B of the Federal Tax Code.

Section A.- Notification of the PRESUMPTION LETTER in accordance with the first and second paragraphs of Article 69-B of the Federal Tax Code, in relation to Article 69 of its Regulations.

R.F.C.	Name, denomination or trade name of the Taxpayer	Number and date of individual presumption letter	Issuing Authority of the individual presumption letter	Notification Medium to the Taxpayer
				Authority's Bench
				Date of posting on the Authority's Bench
1	ACM180628LN8	APRNK COMERCIALIZADORA DE MÉXICO, S.A.S. DE C.V.	500-05-2023-26169 dated December 05, 2023	Central Administration of Strategic Taxation
2	CER170817RT4	CONTACTOS EMPRESARIALES DE REYNOSA, S.A. DE C.V.	500-05-2024-2071 dated January 08, 2024	Central Administration of Strategic Taxation
3	CMA150514MY7	COMERCIALIZADORA MAZUNTE, S.A. DE C.V.	500-05-2024-2077 dated January 09, 2024	Central Administration of Strategic Taxation
4	EVE171124SK3	EXPORT 23, S.C.	500-05-2024-2078 dated January 09, 2024	Central Administration of Strategic Taxation
5	RDC050928SZ0	RUISANCHEZ DISEÑO Y CONSTRUCCIÓN, S.A. DE C.V.	500-36-07-01-03-2023-6188 dated June 02, 2023	Disaggregated Administration of Fiscal Audit of Mexico "2"
6	SIN200710H53	SHUFFLE INVEST, S.A. DE C.V.	500-05-2024-2073 dated January 08, 2024	Central Administration of Strategic Taxation
7	TRI160315CQA	TRIMANI, S.A. DE C.V.	500-05-2023-21360 dated September 28, 2024	Central Administration of Strategic Taxation
8	VAND861113432	DULCE DANIELA VAZQUEZ NAVARRO	500-05-2024-2072 dated January 08, 2024	Central Administration of Strategic Taxation

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

R.F.C.	Name, denomination or trade 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	ACM180628LN8	APRNK COMERCIALIZADORA DE MÉXICO, S.A.S. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
2	CER170817RT4	CONTACTOS EMPRESARIALES DE REYNOSA, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
3	CMA150514MY7	COMERCIALIZADORA MAZUNTE, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
4	EVE171124SK3	EXPORT 23, S.C.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
5	RDC050928SZ0	RUISANCHEZ DISEÑO Y CONSTRUCCIÓN, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
6	SIN200710H53	SHUFFLE INVEST, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024
7	TRI160315CQA	TRIMANI, S.A. DE C.V.	500-05-2023-21490 dated October 09, 2023	Central Administration of Strategic Taxation	October 09, 2023
8	VAND861113432	DULCE DANIELA VAZQUEZ NAVARRO	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	January 17, 2024

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

R.F.C.	Name, denomination or trade 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	ACM180628LN8	APRNK COMERCIALIZADORA DE MÉXICO, S.A.S. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
2	CER170817RT4	CONTACTOS EMPRESARIALES DE REYNOSA, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
3	CMA150514MY7	COMERCIALIZADORA MAZUNTE, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
4	EVE171124SK3	EXPORT 23, S.C.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
5	RDC050928SZ0	RUISANCHEZ DISEÑO Y CONSTRUCCIÓN, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
6	SIN200710H53	SHUFFLE INVEST, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024
7	TRI160315CQA	TRIMANI, S.A. DE C.V.	500-05-2023-21490 dated October 09, 2023	Central Administration of Strategic Taxation	December 01, 2023
8	VAND861113432	DULCE DANIELA VAZQUEZ NAVARRO	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Taxation	February 23, 2024

Section D.- Notification of the DEFINITIVE RESOLUTION letter in accordance with the fourth paragraph of Article 69-B of the Federal Tax Code.

R.F.C.	Name, denomination or trade name of the Taxpayer	Number and date of definitive resolution	Issuing Authority of the definitive resolution	Notification Medium to the Taxpayer
				Authority's Bench
				Date of posting on the Authority's Bench
1	ACM180628LN8	APRNK COMERCIALIZADORA DE MÉXICO, S.A.S. DE C.V.	500-05-2024-12654 dated May 22, 2024	Central Administration of Strategic Taxation
2	CER170817RT4	CONTACTOS EMPRESARIALES DE REYNOSA, S.A. DE C.V.	500-05-2024-12655 dated May 22, 2024	Central Administration of Strategic Taxation
3	CMA150514MY7	COMERCIALIZADORA MAZUNTE, S.A. DE C.V.	500-05-2024-12656 dated May 22, 2024	Central Administration of Strategic Taxation
4	EVE171124SK3	EXPORT 23, S.C.	500-05-2024-12689 dated May 22, 2024	Central Administration of Strategic Taxation
5	RDC050928SZ0	RUISANCHEZ DISEÑO Y CONSTRUCCIÓN, S.A. DE C.V.	500-36-07-01-03-2024-7044 dated May 08, 2024	Disaggregated Administration of Fiscal Audit of Mexico "2"
6	SIN200710H53	SHUFFLE INVEST, S.A. DE C.V.	500-05-2024-12692 dated May 23, 2024	Central Administration of Strategic Taxation
7	TRI160315CQA	TRIMANI, S.A. DE C.V.	500-05-2024-6698 dated March 05, 2024	Central Administration of Strategic Taxation
8	VAND861113432	DULCE DANIELA VAZQUEZ NAVARRO	500-05-2024-12690 dated May 22, 2024	Central Administration of Strategic Taxation

Section E.- Additional data of the taxpayers.

R.F.C.	Name, denomination or trade name of the Taxpayer	Fiscal Address	Predominant Activity	Reason for the Procedure
1	ACM180628LN8	APRNK COMERCIALIZADORA DE MÉXICO, S.A.S. DE C.V.	Querétaro, Querétaro	Wholesale sales by commission and consignment.
2	CER170817RT4	CONTACTOS EMPRESARIALES DE REYNOSA, S.A. DE C.V.	Reynosa, Tamaulipas	Wholesale trade of machinery and equipment for other services and for commercial activities.
3	CMA150514MY7	COMERCIALIZADORA MAZUNTE, S.A. DE C.V.	Ecatepec de Morelos, State of Mexico	Wholesale trade of clothing.
4	EVE171124SK3	EXPORT 23, S.C.	Azcapotzalco, Mexico City	Other Business Support Services.
5	RDC050928SZ0	RUISANCHEZ DISEÑO Y CONSTRUCCIÓN, S.A. DE C.V.	Ecatepec de Morelos, State of Mexico.	Wholesale trade of metallic materials.
6	SIN200710H53	SHUFFLE INVEST, S.A. DE C.V.	Huixquilucan, State of Mexico	Management Consulting Services.
7	TRI160315CQA	TRIMANI, S.A. DE C.V.	Monterrey, Nuevo León	Accounting and audit services.
8	VAND861113432	DULCE DANIELA VAZQUEZ NAVARRO	Reynosa, Tamaulipas	Wholesale trade of other general use machinery and equipment

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