This blog was last updated on January 13, 2020

A new wrinkle in Mexican electronic invoicing adds complexity to the e-invoicing process for maquiladoras, or foreign-owned factories operating along the US-Mexico border. 

Compared to some other countries in Latin America, Mexico has kept its core electronic invoice, the CFDI, relatively simple. Whereas an invoice in Chile has 250 fields or more of required information, the CFDI only has about 50. But that doesn’t mean Mexican e-invoicing isn’t complex. 

Supplements in Mexican e-invoicing 

Mexico pursued a different approach, requiring supplements, or complementos, to invoices for different business and transaction types. Complementos are add-ons to the core CFDI that contain specific information about the nature of a transaction. For instance, there is a complemento for reception of payments (complemento de pagos) and another for companies operating in the oil and gas industry.

Another type of complemento, the complemento de leyendas, has found its way to maquiladoras. It concerns transactions involving virtual importation–essentially components of larger products. For instance, an automaker makes cars in Mexico. Those cars have tires. The automaker pays VAT on the purchase of tires from a supplier, but when the tires leave the factory, they are part of a car and no longer taxed separately. The same idea works for, say, sugar in soda. Those transactions require a complemento de leyendas to accompany the core CFDI. 

Complemento de Leyendas extended to maquiladoras 

The SAT, the Mexican tax administration, recently extended the complemento de leyendas requirement to maquiladoras, meaning the border factories will now have to file supplements for transactions involving all sorts of components of their finished products. The new requirement adds complexity to an e-invoicing process that is already one of the most complicated and difficult to manage in the world.

In order to maximize efficiency and reduce risk, companies classified as maquiladoras (IMMEX) need to be able to automate the process of extracting information for the CFDI and the complemento and publishing it according to government requirements. They also need to have invoice information automatically available in SAP, with a function that will automatically populate SAP tables for each invoice submitted or received. 

It’s also important for maquiladora operators to be able to keep up with the constant changes in Mexican e-invoicing mandates given the ultimately futility of trying to track and incorporate them into systems in-house. As the new maquiladora mandate demonstrates, e-invoicing in Mexico is only going to continue to become more complex.