Official Letter 500-05-2025-17218 Communicating the Definitive Global List under Article 69-B, Paragraph Four of the Federal Tax Code

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DOF: 11/07/2025

OFFICIAL LETTER 500-05-2025-17218 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 Audit.

OFFICIAL LETTER: 500-05-2025-17218

Subject:

The definitive global list is communicated 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 paragraph, 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, in effect 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 Customs Agency of Mexico are issued, published in the same official organ on December 21, 2021, in effect from January 1, 2022, in accordance with the provisions of the First Transitory Article of said Decree; Article Third, fraction I, subsection a), of the Agreement by which various powers are delegated to Public Servants of the Tax Administration Service, published in the Official Gazette of the Federation on June 23, 2016, in effect 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 notice to each of the taxpayers mentioned in said Annex 1, and in said notice, the reasons and grounds were indicated for which the taxpayers fell under 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 by 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 foregoing in accordance with the precedence established in Article 69, first paragraph of the Regulations of the Federal Tax Code in effect, in relation to Article 135 of the Federal Tax Code.

In accordance with 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 rebut the facts known through said 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 rebut 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 trade names in the list of taxpayers who did not rebut the facts known 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 preceding 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 for in said legal provision, presented, through the means indicated in the individual resolutions themselves, various information, documentation, and arguments in order to rebut the facts known in the individual notices indicated above, 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 rebut the facts imputed to them in the individual presumption notices already indicated, the same 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 rebut 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 foregoing, and taking into account that the fourth paragraph of Article 69-B of the Federal Tax Code states that in no case 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 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 trade names of the taxpayers indicated in Annex 1 of this official letter, to the list of taxpayers who did not rebut 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, 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, as declared by the fifth paragraph of Article 69-B of the Federal Tax Code; the foregoing, since it is in the public interest to stop the invoicing 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, June 2, 2025. - 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 effect, signs: C.P. Nayeli Margarita Ramos Hernández, Administrator of Strategic Audit "7".- Rubric.

Annex 1 of official letter number 500-05-2025-17218 of date June 2, 2025, corresponding to taxpayers who DID provide arguments and/or evidence, but DID NOT rebut 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 trade name of the Taxpayer	Number and date of individual presumption notice	Issuing Authority of the individual presumption notice	Notification Medium to the Taxpayer
				Authority's Public Notice Board
				Date of posting on the Tax Authority's Public Notice Board
1	CPM1508313A0	CONSTRUCTORA DEL PACIFICO MUMU, S.A. DE C.V.	500-18-00-05-01-2024-2156 of date November 11, 2024	Administration Disaggregated of Fiscal Audit of Colima "1"
2	FLE1501282A0	FLEXOMERK, S.C.	500-55-00-03-00-2018-1760 of date October 18, 2018	Administration Disaggregated of Fiscal Audit of Sonora "2"

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 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	CPM1508313A0	CONSTRUCTORA DEL PACIFICO MUMU, S.A. DE C.V.	500-05-2024-26177 of date December 13, 2024	Central Administration of Strategic Audit	13 of December of 2024
2	FLE1501282A0	FLEXOMERK, S.C.	500-05-2018-29883 of date November 6, 2018	Central Administration of Strategic Audit	06 of November of 2018

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 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	CPM1508313A0	CONSTRUCTORA DEL PACIFICO MUMU, S.A. DE C.V.	500-05-2024-26177 of date December 13, 2024	Central Administration of Strategic Audit	24 of January of 2025
2	FLE1501282A0	FLEXOMERK, S.C.	500-05-2018-29883 of date November 6, 2018	Central Administration of Strategic Audit	03 of December of 2018

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 trade name of the Taxpayer	Number and date of definitive resolution	Issuing Authority of the definitive resolution	Notification Medium to the Taxpayer
				Authority's Public Notice Board
				Date of posting on the Tax Authority's Public Notice Board
1	CPM1508313A0	CONSTRUCTORA DEL PACIFICO MUMU, S.A. DE C.V.	500-18-00-05-01-2025-924 of date March 19, 2025	Administration Disaggregated of Fiscal Audit of Colima "1"
2	FLE1501282A0	FLEXOMERK, S.C. // In compliance with the sentence of date February 17, 2023, issued by the Regional Court of the North Center IV and Auxiliary, within the Nullity Trial 2470/20-03-02-2.	500-55-00-03-00-2024-374 of date October 18, 2024	Administration Disaggregated of Fiscal Audit of Sonora "2"

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	CPM1508313A0	CONSTRUCTORA DEL PACIFICO MUMU, S.A. DE C.V.	COLIMA, COLIMA	WHOLESALE TRADE OF COMPUTING; OTHER CIVIL ENGINEERING CONSTRUCTIONS, CONSTRUCTION OF COMMERCIAL, INSTITUTIONAL AND SERVICE BUILDINGS, SINGLE-FAMILY DWELLING
2	FLE1501282A0	FLEXOMERK, S.C.	ZAPOPAN, JALISCO	BUSINESS ADMINISTRATION SERVICES

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