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La LCO fue actualizada por última vez el 19/abr/2025

List of taxpayers with alleged simulated operations

PRODECON WARNS ABOUT SIMULATED TRANSACTIONS THROUGH DIGITAL TAX RECEIPTS. Article 69-B of the Federal Tax Code was created to monitor and detect transactions for tax evasion purposes. With this information, the SAT issues its "black list," which contains the names of both shell companies, known as EFOS, and taxpayers who have been detected purchasing their Digital Tax Receipts, known as EDOS. This leads both to be included in the scheme of fraudulent operations that may involve one or more crimes.

EDOS (Companies That Deduct Simulated Operations):

These are responsible for accounting for transactions generated by EFOS to simulate expenses for nonexistent operations and avoid paying taxes to the authorities.

EFOS (Simulated Invoicing Companies):

These companies simulate sales transactions for products or services that aren't real. They lack assets, personnel, or physical infrastructure. They open bank accounts and close them quickly. They have high turnover and few or no expenses. They are untraceable because they are not located at the tax domicile or vacate it without notice. Their corporate purpose is very broad or involves intangible assets, allowing them to offer invoices tailored to the buyer's activities.

Once the SAT detects and notifies the taxpayer that they meet the EFOS criteria, they will be placed on a list and cannot be removed from it. However, they can, through a process, disprove the listing. This can take several months. If this is successful, the taxpayer will not be removed from the list but their status will be changed to "Disproved."

To better understand the possible statuses, the following is an explanation of the possible statuses:

PRESUMPTIVE:
When the tax authority detects that a taxpayer has been issuing receipts irregularly, the transactions covered by those receipts will be presumed nonexistent.

In this case, the tax authority will notify taxpayers in this situation through their tax mailbox, the Tax Administration Service website, and through publication in the Official Gazette of the Federation.

DISTORTED:
When the taxpayer provides the tax authority with the documentation and information they consider relevant to refute the facts that led to their notification, within a period of fifteen days from the last notification issued.

FINAL:
If the taxpayer does not respond to the authority's notification within fifteen days of the last notification, or if the taxpayer cannot disprove the existence of their transactions, this status will be published.

FAVORABLE RULING:
The taxpayer has thirty days to prove that their transactions are genuine. If they manage to correct their situation, this status will be published.

Legal Basis:
Tax Code, Article 69-B.

At SOLUCION FACTIBLE, we have the tools to prevent the issuance and receipt of invoices by EFOs and EDOs.

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