Mexico: Changes to VAT Obligations, E-Signature and E-Invoicing

Ramón Frias
September 10, 2020

Part 2: Main Aspects of the 2nd Modification of the Miscellaneous Fiscal Resolution for 2020

In addition to the provisions related to digital services explained in Part I of this blog, the second Modification to the Miscellaneous Fiscal Resolution for 2020 (RMF2020) also introduced the following changes related to VAT obligations, the use of electronic signature and the electronic invoicing mandate:

Modification of the VAT Withholding Percentage for Staffing Services: The language of the Rule 11.4.18 of the Miscellaneous Fiscal Resolution for 2020, was modified to specify that the withholding applicable for the payment of staffing services will be 50% of the rate (6%) specified on Article 1-A, Fraction IV of the VAT law. This reduced rate will be applied directly to the price paid for the transactions related to those services.

Refund of Excess VAT Paid: A new rule has been added to condition the refund of excess VAT paid by entities, to the previous filing of the DIOT of the corresponding period. The DIOT is an informational return of transactions with third parties, where taxpayers inform the SAT about the payments, withholdings, credits and VAT applied on their purchase transactions carried out with their suppliers.

Mandatory Use of Fiscal Mailbox: In general, the deadlines for enabling and using the fiscal mailbox were unchanged: Legal entities should start using those electronic fiscal mailboxes (buzon tributario electronico) by 30 September 2020, while individuals should start using them by 30 November of this year. However, a new provision was added to specify that those individuals assimilated to the regime of salaried personnel with revenues equal or above 3 million pesos during the last fiscal period, should enable that fiscal mailbox by 15 July 2020.

Supplement of the CFDIs for Sales of Hydrocarbons and Petroleum Fuels: A new rule has been added to mandate the incorporation to the supplement of the electronic invoice (CFDI) related to fuels, the number of the contract for the exploration and extraction of hydrocarbons or the permit of Regulatory Commission of the Energy of the Ministry of Energy.

Electronic Signature: Several provisions have been included regarding the use of the electronic signature by individuals. Some are intended to restrict or to help individuals issue electronic invoices (CFDI) using the certificate of electronic signature (e.firma) instead of the digital seal certificate (Certificado de Sello Digital or CSD). The rules related of the procedures intended to generate, renew, suspend, or permanently revoke the certificate of electronic signature, were also amended in RMF2020.

Extension of Permission to Use of Global CFDIs by Sellers of Fuels: This second modification of the Miscellaneous Fiscal Resolution postpones until 31 December 2020 the permission given to sellers of fuels to issue global electronic invoices (CFDIs) for their sales of fuels subject to volumetric controls. This permission was supposed to end on 31 July 2020. This means that from 1 January 2021, those taxpayers are required to issue a CFDI for each sale of fuel made to their customers. This provision can be found in Art. Tercero that modifies the twenty seventh Article of the 2020 Miscellaneous Fiscal Resolution.

Further details of the provisions of the second modification of the miscellaneous fiscal resolution,  can be found here.

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Ramón Frias

Ramon is a Tax Counsel on the Regulatory Analysis team at Sovos. He is licensed to practice law in the Dominican Republic and is a member of the Dominican Bar Association. He has a Certificate Degree from Harvard University as well as a J.D. from the Universidad Autonoma de Santo Domingo. Ramon has written a number of essays about tax administration and has won the first prize in the international essays contest sponsored by the Inter American Center of Tax Administrations (CIAT). Prior to joining Sovos, Ramon worked for more than 10 years in the Department of Revenue of the Dominican Republic where he served as Deputy Director. He is proficient in French and Spanish.
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