Official Letter 500-05-2024-18622 Communicating the Definitive Global List under Article 69-B, Paragraph Four of the Federal Tax Code

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DOF: 10/18/2024

OFFICIAL LETTER 500-05-2024-18622 communicating the definitive global list under Article 69-B, paragraph four of the Federal Tax Code.

At the margin, a seal with the National Emblem, 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 Audit.

Official Letter: 500-05-2024-18622

Subject:

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

The Central Administration of Strategic Audit, 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 the aforementioned 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 notice to each of the taxpayers mentioned in the aforementioned Annex 1, and in said notice, the reasons and grounds were indicated for which the taxpayers fell into the hypothesis referred to in the first paragraph of Article 69-B of the Federal Tax Code.

Now, the individual notices 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 thereof.

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 thereof, 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 the provisions of the second paragraph of Article 69-B of the Federal Tax Code, in the individual presumption notices, 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 refute the facts made known through the aforementioned notices, warned that if, after the granted period had elapsed, they did not provide the documentation and information and/or what they exhibited, once evaluated, did not refute the facts indicated in the notices in question, the authorities would proceed, in terms of the fourth paragraph of Article 69-B of the Federal Tax Code, first to notify them of the definitive individual resolution, as well as to publish their names, denominations, or corporate names in the list of taxpayers who did not refute the facts made known and therefore, would be in a definitive situation referred to in the first paragraph of the aforementioned Article 69-B of the Federal Tax Code.

Once the period indicated in the previous paragraph had 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, in exercise of the right provided in the aforementioned legal provision, presented, through the means indicated in the individual resolutions themselves, various information, documentation, and arguments in order to refute the facts made known in the aforementioned individual notices, and said authorities proceeded to the admission and evaluation of the same.

As a result of the evaluation mentioned in the preceding paragraph, and in view of the fact that with the arguments manifested and evidence provided by those taxpayers, the aforementioned authorities considered that those taxpayers did not refute the facts imputed to them in the individual presumption notices already indicated, they resolved what was appropriate and proceeded to the issuance of the definitive resolutions in which the reasons, motives, and grounds were indicated for why they did not refute said facts; resolutions that were duly notified in the terms indicated in the preceding paragraphs to each of the taxpayers indicated in Annex 1, section D, of this official letter.

For the above stated and, taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code states that under no circumstances will the list be published before the thirty business days following the notification of the resolution and that, at the 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 the aforementioned definitive resolutions, this Central Administration of Strategic Audit, 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 the present, proceeds to add the names, denominations, or corporate names of the taxpayers indicated in Annex 1 of this official letter, to the list of taxpayers who did not refute the facts imputed to them and therefore, are in a definitive situation referred to in the first paragraph of the aforementioned Article 69-B of the Federal Tax Code, for the reasons and grounds indicated in the definitive resolutions notified to each of them, a 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 did not produce nor did they produce 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.

Sincerely.

Mexico City, September 25, 2024. - In substitution for the absence of the Central Administrator of Strategic Audit, by 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, 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 Audit "7".- Rubric.

Annex 1 of official letter number 500-05-2024-18622 dated September 25, 2024, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT refute the reason for which they were notified of the presumption notice, 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 NOTICE 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 corporate name of the Taxpayer	Number and date of individual presumption notice	Issuing authority of the individual presumption notice	Notification means to the taxpayer
				Court records of the authority / Personal notification / Tax Box Notification
				Date of posting on court records of the Fiscal Authority / Date on which notification took effect
1	AYO210811UH6	ADMINISTRADORA YOKUT, S.A. DE C.V.	500-32-00-03-04-2023-8803 dated December 07, 2023	Decentralized Administration of Fiscal Audit of Jalisco "3"
2	DKG1805143T0	DISTRIBUCIONES KG, S.A. DE C.V.	500-05-2019-35963 dated October 31, 2019	Central Administration of Strategic Audit
3	ROGD860408U39	RODRIGUEZ GIL DANIEL	500-51-00-01-01-2024-07761 dated February 07, 2024	Decentralized Administration of Fiscal Audit of Sinaloa "1"

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

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of global presumption notice	Issuing authority of the global presumption notice	Date of notification on the internet page of the Tax Administration Service	Date on which notification took effect
1	AYO210811UH6	ADMINISTRADORA YOKUT, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Audit	17 January 2024
2	DKG1805143T0	DISTRIBUCIONES KG, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	02 December 2019
3	ROGD860408U39	RODRIGUEZ GIL DANIEL	500-05-2024-12626 dated May 06, 2024	Central Administration of Strategic Audit	06 May 2024

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

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of global presumption notice	Issuing authority of the global presumption notice	Date of notification in the Official Gazette of the Federation	Date on which notification took effect
1	AYO210811UH6	ADMINISTRADORA YOKUT, S.A. DE C.V.	500-05-2024-6487 dated January 17, 2024	Central Administration of Strategic Audit	23 February 2024
2	DKG1805143T0	DISTRIBUCIONES KG, S.A. DE C.V.	500-05-2019-36144 dated December 02, 2019	Central Administration of Strategic Audit	26 December 2019
3	ROGD860408U39	RODRIGUEZ GIL DANIEL	500-05-2024-12626 dated May 06, 2024	Central Administration of Strategic Audit	20 June 2024

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

R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of definitive resolution	Issuing authority of the definitive resolution	Notification means to the taxpayer
				Court records of the authority / Personal notification / Tax Box Notification
				Date of posting on court records of the Fiscal Authority / Date on which notification took effect
1	AYO210811UH6	ADMINISTRADORA YOKUT, S.A. DE C.V.	500-32-00-03-04-2024-3951 dated May 28, 2024	Decentralized Administration of Fiscal Audit of Jalisco "3"
2	DKG1805143T0	DISTRIBUCIONES KG, S.A. DE C.V. // In compliance with what resolved by the Regional Chamber of the Northwest II, of the Federal Tribunal of Administrative Justice, within the Nullity Lawsuit 1192/20-02-01-8	500-05-2024-18338 dated August 02, 2024	Central Administration of Strategic Audit
3	ROGD860408U39	RODRIGUEZ GIL DANIEL	500-51-00-01-01-2024-47844 dated August 14, 2024	Decentralized Administration of Fiscal Audit of Sinaloa "1"

Section E.- Additional data of the taxpayers.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Fiscal Address	Predominant Activity	Reason for the Procedure
1	AYO210811UH6	ADMINISTRADORA YOKUT, S.A. DE C.V.	Zapopan, Jalisco	Accounting and audit services
2	DKG1805143T0	DISTRIBUCIONES KG, S.A. DE C.V.	Hermosillo, Sonora	Other Retail Trade Intermediaries
3	ROGD860408U39	RODRIGUEZ GIL DANIEL	Monterrey, Nuevo León	Salaried worker

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