Deadline to use CFDI 4.0 extended for taxpayers obliged to issue Payroll CFDIs until March 31, 2023
An update on the preliminary draft of the Ninth resolution of modifications to the Miscellaneous Tax Resolution ("RMF") for 2022 has been published on the website of the Tax Administration Service in Mexico (also known as the SAT).
This update indicates via its Fifth Transitory article that taxpayers obliged to issue Payroll CFDIs can choose to continue issuing them in version 3.3 with payroll supplement version 1.2 until 31 March 2022.
The CFDI 4.0, and associated documents including the payment receipt, are still scheduled to be mandatory from 1st
Taxpayers required to issue CFDI Payroll will have an additional period to complete their work to collect the tax data of workers (RFC, Name and Postal Code) required for the issuance of CFDI 4.0, as well as well as to verify that these are aligned with the information registered in the SAT databases. The requirement to validate this information against the SAT database
was introduced by the SAT earlier this year.
Extension for mandatory CFDI 4.0 usage to 1 January 2023
Tungsten Network has closely been monitoring timeframes around the inception of the mandatory usage of CFDI 4.0 and associated documents in Mexico. Mandatory usage of the CFDI 4.0 and associated documents has been postponed several times.
Once again, mandatory usage of these documents has been delayed. The Mexican Tax Authorities, Servicio de Administracion Tributaria (SAT) have confirmed via a press release that the mandatory usage of the CFDI 4.0 has been extended to 1st
This means that taxpayers can invoice using CFDI 3.3 or 4.0 until 31st
December 2022. Note that Tungsten network is ready to process both CFDI 3.3 and 4.0 invoices as well as both versions of the payment receipt.
The press release published by the SAT can be found here
Tool for validation of electronic invoice data
The Mexican government has imposed some further requirements regarding the mandatory tax data required on the CFDI 4.0.
In addition to the introduction of the CFDI 4.0, which now becomes mandatory as of 1st
January 2023 (see update above), the following tax data of the CFDI’s recipient will also be mandatory. This data must also be updated and matched with the information on the Mexican Tax Authorities’ database:
- Mexican tax Id (RFC)
- Legal name
- Tax regime
- Zip code
Consequently, businesses will need to collect the form ‘Constancia de Situacion Fiscal’ (proof of tax situation) from the CFDI recipients.
There are several Mexican Tax Authority application forms from which taxpayers can validate this information, including:
Tungsten Network is analysing the requirements for the new mandatory tax data in the CFDI 4.0 and is working on a solution to ensure these are integrated into our service offering to our customers.
Deadline fast approaching for transition to CFDI version 4.0
In line with recent updates, you will be aware that the CFDI 4.0 and the Payment Receipt 2.0 in Mexico will become mandatory to use from 1st July 2022.
CFDI 3.3 will not be compliant from 1st July 2022 onwards, which means that it will be rejected on and after this date. To this effect, it’s imperative that businesses are prepared to accommodate CFDI 4.0 in advance of 1st July 2022 onwards. Tungsten will support the new version.
Further extension to the transitional period for the Carta Porte
The original timeline communicated by the tax administration in Mexico, the Servicio de Administracion Tributaria (SAT), was that CFDI 4.0 and Carte Porte was to become mandatory from 1 May 2022, with a transition period between 1 January and 30 April 2022.
The SAT subsequently announced that the mandatory usage of CFDI 4.0 was delayed by a further 2 months, to become mandatory as of 30 June 2022. However, more recently on 9 March 2022, the Mexican Tax Administration issued a press release indicating that the transitional period has been further extended up until 30 September 2022 for the Carta Porte.
The CFDI 4.0 and associated documents continues, for now, to be mandatory from 30 June 2022. The usage of these documents continues to be optional up until 30 June 2022.
Tungsten Network has successfully been able to process the Carta Porte since January 2022.
Delay of mandatory implementation of CFDI version 4.0
The new CFDI version 4.0, which is intended to replace CFDI version 3.3, was due to become mandatory on 1 May 2022.
The tax administration in Mexico, Servicio de Administracion Tributaria (SAT) subsequently announced that the mandatory usage of CFDI 4.0 was delayed again by a further 2 months, to become mandatory as of 30 June 2022. However, more recently on 9 March 2022, the Mexican Tax Administration issued a press release indicating that the transitional period has been further extended up until 30 September 2022. This extension also applies to version 2.0 of the withholding and payment information in respect of the CFDI. The usage of these documents continues to be optional up until 30 September 2022.
This delay affords many companies with much needed time to adjust to the new changes. This extension also applies to version 2.0 of the withholding and payment information in respect of the CFDI.
Tungsten Network is reviewing its own implementation plans to accommodate the new CFDI version 4.0 considering the revised timeframes.
Background to digital tax & proposal of new digital tax
Fiscal measures that countries are deploying also demonstrate how obligations for digital businesses are coming more sharply into focus.
Mexico is planning to enact a 2% Digital Services Tax on commission received by online marketplaces. Funds raised will be spent on improving Mexico City’s infrastructure.
This builds on earlier taxation developments in the digital landscape in Mexico which took place in Mexico in June 2020, where Mexico applied 16% VAT on digital services provided by foreign businesses.
The Mexican Tax Authorities have published a list of non-resident companies that have registered for VAT further to the introduction of Mexico’s new digital VAT obligations in June 2020. There is a wide scope of companies affected, showing the extent of companies affected by the digital VAT obligations.
With digital obligations becoming more prevalent globally, we can expect to see other countries enacting similar measures in 2022.
Transition period introduced for the Carta Porte version 2.0
We previously advised that the Carta Porte- a new transportation note that forms part of the CFDI- is mandatory to use from 1st January 2022. Tungsten can successfully process the new version.
Even though this is mandatory to use from 1st January 2022 (with the exception of certain foreign trade transactions, for which this is not mandatory until 31 March 2022), the Mexican tax authorities issued a statement on 24 December 2021 indicating a transition period from 1st January 2022 to 31 March 2022, where e-invoices can be corrected without being subject to penalties.
Mexico has also made it easier for domestic traders that perform exports under 30 kilometres on federal highways by ‘light load vehicles’- taxpayers falling under this scope will not need to complete the Carta Porte 2.0.
Our local partner Buzone has prepared a webinar which provides useful information around the Carta Porte, including error codes relating to the new version.
Complemento Carta Porte 2.0 – updated version
We have provided some guidance around the Carta Porte – the new transportation notes that forms part of the CFDI. An updated version of the Complemento Carta Porte version 2.0 was published on the Mexican Tax Administration (SAT) website. This is mandatory from 1 January 2022. The updated version can be found here.
Tungsten has processed all the updated changes in our system, including the updated error codes, and we can process the updated Carta Complemento version.
Introduction of the new CFDI version 4.0 in January 2022
While the Mexican Government was still making changes through December 2021, we were working urgently to analyse what this means for Tungsten customers. As a reminder, a testing period began on 1 January 2022, up until 1 May 2022, at which point it will be mandatory to use the CFDI 4.0. It is still possible that the timelines will change. During the testing phase, both CFDI versions (3.3 and 4.0) can be used.
The new CFDI 4.0 version can be found on the Mexican government website.
CFDI version 4.0.
The tax authorities in Mexico are in the process of releasing new requirements for a new version of the legal invoice in Mexico, known as the CFDI. This will be updated to version 4.0.
The new version of the CFDI will become enforceable from 1 April 2022, with a testing phase from 1st January 2022. Suppliers will be able to send over CFDIs in the new format prior to 1st April 2022.
Tungsten Network is aware of these changes and is analysing the requirements.
Final technical specifications are yet to be published but we expect these soon from the tax authorities.
Delay for ‘Carta Porte’ implementation
The implementation of the ‘Carta Porte’ was due to go ahead on 1st October 2021. All Mexican taxpayers that transport goods and merchandise in Mexican territory via sea, air, rail or federal highways are required to include this in the Mexican legal invoice artefact (the CFDI).
This requirement to include the Carta Porte has now been delayed until 1st January 2022.
Mexico mandates CFDI version 3.3
Mexico CFDI 3.3 was introduced on 1 July 2017 and becomes mandatory from today. The new version includes changes in structure, data format, catalogues, as well as invalidations and calculation rules such as the following.