Official Letter 900-04-00-00-00-2024-80 Communicating the Definitive Global List Under Article 69-B Bis of the Federal Tax Code

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DOF: 05/07/2024

OFFICIAL LETTER 900-04-00-00-00-2024-80 communicating the definitive global list under Article 69-B Bis, ninth paragraph 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 Large Taxpayers.- Central Administration for Taxation of Various Large Taxpayers.

Official Letter: 900-04-00-00-00-2024-80.

Subject:

Communicating definitive global list under

Article 69-B Bis, ninth paragraph of the Federal

Tax Code.

The Central Administration for Taxation of Various Large Taxpayers, headquartered in Mexico City, attached to the General Administration of Large Taxpayers, of the Tax Administration Service, based on what is established in Articles 16, first paragraph, of the Political Constitution of the United Mexican States; 17 and 31, fractions XI and XXXII of the Organic Law of the Federal Public Administration; 1, 2, 3, 4, fractions VII, XII and XVIII and 8, fraction 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 on June 12, 2003; 1, 2, first paragraph, Section B, fraction V, subsection d) and second paragraph, 5, first paragraph, 13, fraction VI, and 28, last paragraph, numeral 4, 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 what is established in 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 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 what is established in the First Transitory Article of said Decree; Article Third, fraction I, subsection a) of the Agreement by which various powers are delegated to the public servants of the General Administrations of Federal Audit, Foreign Trade Audit, Large Taxpayers and Hydrocarbons of the Tax Administration Service, published in the Official Gazette of the Federation on October 22, 2018, in effect from November 1, 2018, in accordance with what is established in the Single Transitory Article of said agreement; in relation to Articles Eighth, fraction V of the Agreement by which the powers of the public servants of the Tax Administration Service are delegated, published in the aforementioned information medium on September 3, 2020 and Fifth, fraction V of the Agreement by which powers are delegated to the public servants of the Tax Administration Service published in the aforementioned information medium on May 19, 2021; as well as in Articles 33, last paragraph, 63 and 69-B Bis, paragraphs first, second, fourth, seventh, ninth and tenth of the Federal Tax Code, informs the following:

As a result of the procedure for the presumption of improper transmission of the right to reduce tax losses provided for in Article 69-B Bis of the Federal Tax Code, the authorities cited in Annex 1, which is an integral part of this official letter, detected that the taxpayers indicated in said Annex 1 carried out the improper transmission of the right to reduce tax losses.

Having detected such a situation, the aforementioned Fiscal Authorities, in order to comply with Article 69-B Bis, fourth paragraph of the Federal Tax Code, issued an individual presumption letter to each of the taxpayers mentioned in the aforementioned 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 Bis 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.

Attending what is established by the fourth paragraph of Article 69-B Bis of the Federal Tax Code, in the individual presumption letters, the fiscal authorities granted the taxpayers a period of twenty business days counted from the last notification made, to make the statements and provide the documentation and information they considered pertinent to refute the facts made known through the aforementioned letters, under the warning that if the granted period elapsed without providing the documentation and information and/or the one exhibited, once evaluated, did not refute the facts indicated in the letters in question, the fiscal authorities would proceed, in terms of the seventh and ninth paragraphs of Article 69-B Bis of the Federal Tax Code, first to notify them of the definitive individual resolution, as well as to publish their name, denomination or corporate name in the list of taxpayers who did not refute the facts made known and, therefore, would be in definitive form in the situation referred to in the first paragraph of the aforementioned Article 69-B Bis of the Federal Tax Code.

Once the period indicated in the previous paragraph has elapsed, and in view of the fact that the taxpayers during the period established in the fourth paragraph of Article 69-B Bis of the Federal Tax Code, in exercise of the right provided for in the aforementioned legal provision, presented, through the means indicated in the individual presumption letters, various information, documentation and arguments, tending to refute the facts made known through said individual letters indicated above, said authorities proceeded to the admission and valuation of the same.

As a result of the valuation mentioned in the preceding paragraph, the aforementioned fiscal authorities considered that the taxpayers did not refute the presumption of the improper transmission of the right to reduce tax losses, so they proceeded to issue the definitive individual resolutions in which it was determined that they did not refute the facts imputed to them, and, therefore, they are definitively in the situation referred to in the first paragraph of Article 69-B Bis of the Federal Tax Code for the reasons exposed in each definitive resolution, which were duly notified to each taxpayer in the terms indicated in Annex 1, Section B of this official letter.

For the aforementioned reasons and, taking into account that the ninth paragraph of Article 69-B Bis 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 referred to in Annex 1 of this official letter that orders the suspension or declares the nullity or revocation of the procedure provided for in the article in reference; therefore, in order to fully comply with Resolutive Third contained in the aforementioned definitive resolutions, to which reference is made in Annex 1, Section B, this Central Administration for Taxation of Various Large Taxpayers, attached to the General Administration of Large Taxpayers, of the Tax Administration Service, in support of the Fiscal Authorities indicated in Annex 1 of this, proceeds to add the name, denomination or corporate name 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 in definitive form in the situation referred to in the first paragraph of the aforementioned Article 69-B Bis 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 confirm, with general effects, the improper transmission of the fiscal losses obtained by the taxpayer who generated them, as well as the inappropriateness of their reduction by the corresponding taxpayer, as declared by the tenth paragraph of Article 69-B Bis of the Federal Tax Code; the above, since it is in the public interest to inhibit practices tending to erode the income tax base through the improper transmission of fiscal losses, as well as for society to know who those taxpayers are who carry out this type of operations.

Sincerely.

Mexico City, January 25, 2024.- Central Administrator for Taxation of Various Large Taxpayers, L.C. Alejandro Alcides Villalta Ramírez.- Electronically signed.

Annex 1 Official Letter number 900-04-00-00-00-2024-80 dated January 25, 2024 through which the definitive global list is communicated under Article 69-B Bis, ninth paragraph of the Federal Tax Code corresponding to the taxpayers who provided documentation and information to refute the presumption referred to in the first paragraph of the aforementioned numeral, but with the same DID NOT refute the facts imputed to them, which is why the hypothesis referred to in the first paragraph of Article 69-B Bis of the Federal Tax Code was DEFINITIVELY updated, for the effects provided for in the tenth paragraph of the aforementioned numeral.

Section A.- Notification of the LETTER OF PRESUMPTION in accordance with paragraphs first, second and fourth of Article 69-B Bis of the Federal Tax Code.

Notification Medium to Taxpayer	R.F.C.	Name, denomination or corporate name of the Taxpayer	Number and date of individual presumption letter	Issuing Authority of the individual presumption letter
Tax Mailbox
Notification Date	Effective Date of Notification
1	OAN151230HWA	OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.	900-04-05-00-00-2022-644 dated October 11, 2022	Administration for Taxation of Various Large Taxpayers "5"
October 11, 2022	October 12, 2022
2	CPH061010RB7	CONSTRUCTORA DE PROYECTOS HIDROELECTRICOS, S.A. DE C.V.	900-04-05-00-00-2022-700 dated November 29, 2022	Administration for Taxation of Various Large Taxpayers "5"
December 2, 2022	December 5, 2022

Section B.- Notification of the LETTER OF DEFINITIVE RESOLUTION in accordance with the seventh paragraph of Article 69-B Bis 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 by Tax Mailbox to the Taxpayer	Notification Date	Effective Date of Notification
1	OAN151230HWA	OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.	900-04-03-00-00-2023-251 dated May 17, 2023	Administration for Taxation of Various Large Taxpayers "3"	May 17, 2023	May 18, 2023
2	CPH061010RB7	CONSTRUCTORA DE PROYECTOS HIDROELECTRICOS, S.A. DE C.V.	900-04-00-00-00-2023-259 dated July 7, 2023	Central Administration for Taxation of Various Large Taxpayers	July 13, 2023	July 14, 2023

Section C.- Additional Data of the Taxpayers.

R.F.C.	Name, denomination or corporate name of the Taxpayer	Fiscal Address	Predominant Activity	Reason for Procedure
1	OAN151230HWA	OPERADORA AUTOPISTAS NACIONALES EQUIVENT, S.A. DE C.V.	Cuajimalpa de Morelos, Mexico City.	Construction of highways, expressways, gravel roads, bridges, overpasses and airstrips.
2	CPH061010RB7	CONSTRUCTORA DE PROYECTOS HIDROELECTRICOS, S.A. DE C.V.	Benito Juárez, Mexico City.	Other civil engineering constructions or heavy work.

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