Understanding Mexico’s Miscellaneous Fiscal Resolution for 2021 and its Modifications (Part II)

Ramón Frias
April 19, 2021

Mexico’s Miscellaneous Fiscal Resolution (MFR) for 2021 includes a number of changes, the first of which you can read about in our previous blog on the subject.

In this blog we will discuss the approved specific technical modifications related to the validations Authorised Certification Providers (PACs) should make to electronic invoices sent to them for certification.

Modifications were introduced in Annex 29 of the MFR that specifically accounts for the rules PACs should follow as providers of certification services for the Mexican tax administration (SAT).

Some of the most important new validations PACs are required to perform on the electronic invoices (CFDIs) are:

A. Form and method of payment: When invoices of Income, Payment or Payroll are issued (also known as Comprobantes de tipo Ingreso, Egreso o Nómina) PACs must validate that they contain the attributes regarding the form and method of payment (FormaPago and MetodoPago). Although these attributes are generally optional, they become mandatory when the invoice is of type ‘I’ (Ingresos), ‘E’ (Egresos) or ‘N’ (Nomina). Any Income, Payment or Payroll CFDIs that lack these attributes or the corresponding catalogs should not be validated by the PACs.

B. Currency Exchange Rate: PACs are required to perform additional validations regarding the exchange rate reported in the attribute ‘TipoCambio’ when payment reported is in a foreign currency. If the value in the invoice is outside the percentage acceptable, the issuer of the invoice should obtain a key from the PAC validating the CFDI to confirm the value is correct.

C. Total: A new interpretation of the attribute ‘total’ of the invoice has been introduced. When the value reported exceeds the limits established by the SAT via Resolution, the issuer of the invoice should include a confirmation key from the PAC validating the CFDI confirming the value is correct. The key should be included in the ‘Confirmacion’ attribute of the CFDI

D. Transfers (Traslados): If a CFDI only includes exempt items, it does not require the ‘traslados’ note that normally contains itemisation of the taxes transferred.

E. “NumeroPedimento”: The number assigned to “Pedimentos” (name given to the return filed when merchandise enters or leaves Mexico) that are more than 10 years old should be registered in the ‘Descripcion; attribute of the document.

F. Other Changes: Withholdings and Payments CFDIs should not include negative numbers. This clarification has been introduced as XSDs and the technical standard of those supplements do not limit or reject the use of negative numbers despite there being no such thing as a negative payment of taxes. It’s now mandatory for PACs to reject any document with negative numbers. Specific processes of cancellation and reissuance have been established for invoices containing errors and in the case of losses there are specific fields where such values should be reported.

PACs must validate that Supplement of Received Payments (Complemento de Recepcion de Pagos) CFDIs contain Payment (Pago) notes and the related document (Documento Relacionado) contains at least one record. The clarification of this requirement has been necessary as these notes are conditional rather than mandatory for XSDs and the technical documentation. The Miscellaneous Fiscal Resolution for 2021 also included new validations regarding the CFDI supplements issued for Financial Factoring and transactions with third parties.

Following the release of the Miscellaneous Fiscal Resolution for 2021, the SAT has issued multiple modifications to supplement the MFR originally approved. Four additional changes have been proposed and/or approved but none have had any major impact on the electronic invoicing mandate.

We expect more changes before the end of the year and will keep you updated via our regulatory feeds and blogs.

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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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