Mexico is one of the oldest pioneers in e-invoicing. With more than 10 years of experience, ~30 billion e-invoices, ~6 billion last year, it is worthwhile to see what the Tax Administration “SAT” has decided to change for the upcoming version 3.3, mandatory as of July 1st this year. As clearance gains more territory, what’s new in this clearance stronghold?
I’ll focus below on the key changes, but would be amiss if I didn’t briefly mention the good operational changes like: fixing flaws, standardized currency codes, catering with time-zones, richer printable representation, stronger signatures, and stricter contents control using several so called ‘catalogues’.
The first notorious key change is that suppliers will not be able to cancel certain CFDI invoices unless the buyer has agreed to that. This barrier was put by SAT to prevent fraud by suppliers who, once paid, cancelled CFDIs to avoid paying output VAT, creating a problem for buyers and the SAT alike.
Another change that we strongly advocated towards SAT is that the signing process includes ERP-generated invoice numbers. SAT didn’t see the need before as cleared invoices already contained another unique CFDI fiscal number assigned by the PAC. But this created problems for enterprises that issued different CFDIs, while SAT treated them as the same. This is another example where compliance and business processes are not at sync.
Finally, a payment ‘complemento’ (sort of appendix inside CFDI) also becomes mandatory. Suppliers will have to issue additional secondary CFDIs containing this ‘complemento’, each time they receive a payment for a transaction supported by a previously issued primary CFDI. In this way, the SAT will have better control of the corresponding tax. Also, as mentioned earlier, a buyer who has (partially) paid for a supply will be able to block any attempt to cancel the primary CFDI.