Regulatory updates - Mexico

The Mexican government has announced an extension of the obligation to issue version 4.0 of the Payroll Digital Fiscal Receipt via the Internet (CFDI). The purpose of this measure is to support taxpayers in complying with their tax obligations.

The extension seeks to provide additional time for companies to adapt to the new regulations and make the transition effectively.

When does the new timeline come into effect?

The new obligation timeline proposed by the SAT is 1 July 2023.

It is recalled that since 31 March 2023, the co-existence period between versions 3.3 and 4.0 of the CFDIs ended, except for the Payroll CFDI. Since 1 April 2023, it is only possible to issue CFDI version 4.0.

Does the change require any actions?

In case a taxpayer has already implemented the Payroll CFDI in version 4.0, no more action is required on their part. If the version has not been implemented, an additional date will be granted, as indicated in the official announcement, .

As previously explained by Pagero, this is not the first time that SAT has been moving the deadlines for issuing the new version of CFDI. With the new timeline, taxpayers will be able to use CFDI 3.3 for all documents until 31 March 2023.

Besides this announcement, SAT has also decided to grant a grace period to taxpayers obliged to issue the Carta Porte complement. The penalties for non-compliance with Carta Porte will begin to be imposed from August 2023.

More details about the announcement by SAT can be found here (in Spanish).

This time extension means taxpayers may issue electronic payroll receipts by using the CFDI version 3.3 until 31 March 2023. However, this time extension doesn’t impact other CFDIs such as e-invoices, credit notes, payment receipts, and other documents. These other documents will still be required to be issued using the CFDI version 4.0 starting January 2023.

You may find more details regarding the announcement by SAT (in Spanish) here. Meanwhile, stay tuned with Pagero to know the latest updates in Mexico.

Therefore, the following operations can be performed until 31 December 2022:

• Cancellation of electronic invoices for fiscal years before 2022;
• Using version 3.3 of CFDI e-invoices (version 4.0 will become mandatory from January 2023, as per the previous update from 15 June);
• Invoice issuance without an e-signature or digital seal certificate requirement (only for taxpayers under the Simplified Trust Regime);
• Activation of e-signature (e.firma) by taxpayers under the Simplified Trust Regime;
• Grace period for taxpayers who still have not enabled their Tax Mailbox or registered/updated their means of contact;
• Further extension of the transition period for issuing the Carta Porte complement without the risk of facing penalties or fines.

As previously reported by Pagero, taxpayers were able to use either the CFDI 3.3 or 4.0 until 30 June 2022. In a recent announcement made by the SAT, the transition period will be extended until 31 December 2022. As of 2023, only CFDI 4.0 will be accepted by the local tax authority.

The reason for this new postponement is to facilitate taxpayers’ compliance with their fiscal obligations.

Currently, taxpayers already using the CFDI 4.0 are recommended by the Mexican Tax Authority to keep using it. At the same time, those who have not implemented it are advised to continue with the transition process within the established period.

As previously reported by Pagero, the electronic invoice with a new mandatory Carta Porte complement version entered into force on 1 January 2022.

However, due to a gradual implementation process by the taxpayers, the Tax Administration Service (SAT) informs in their press release that the transition period will be extended until 30 September 2022.

Until 30 June 2022, both CFDI versions 3.3 and 4.0 can be used. Version 4.0, which will be used exclusively as of 1 July 2022, comes with updates that include:

• Registration of multiple related invoices
• Updates to cancellation methods
• Ability to include export information

Pagero has provided additional information regarding the transition from CFDI version 3.3 to version 4.0 in previous publications.

Read the full announcement from the Mexican Tax Authority here.

The Mexican Tax Authority has recently published new timelines for the taxpayers to upgrade to version 2.0 of Carta Porte.

All invoices issued in Mexico and related to transported goods will have to contain the new complement Carta Porte 2.0 latest by 1 January 2022. During December 2021, the use of the new complement version on invoices stays optional.

In case an invoice is issued without the Carta Porte version 2.0 after December 2021, suppliers might get fines from the Tax Authority, ranging between MXN 760 and MXN 14 710,00 (ca. EUR 32-622). Furthermore, the buyers will not be able to deduct any input VAT from invoices not containing this complement.

The technical specifications for the Carta Porte complement version 2.0 are available in Spanish here.

This change is expected to enter into force in 2022. Until 30 April 2022, both versions (3.3 and 4.0) will be allowed. As of 1 May 2022, the CFDI version 4.0 will become mandatory.

These are benefits of the new version for the taxpayers:

• Reporting more accurate information from the CFDI to the SAT to increase efficiency in SAT’s clearance responses;
• Facilitation of the VAT declarations with pre-filled information derived from the data provided in the CFDI.

New features are added to the new version, among others:

• Export purposes: to indicate if the CFDI covers an export operation;
• Recipient address: to register the postal code address of the CFDI recipient;
• Recipient tax regime: to add the tax regime of the recipient to whom the CFDI tax effect will apply;
• Taxable object: to indicate whether the commercial operation is taxable or not;
• New validation rules to be introduced;
• Reason for cancellation to be stated in the CFDI.

The technical documentation, validation rules and other specific changes are expected to be published soon by the SAT on their website.