Deadline for the implementation of the new electronic invoicing 4.0 ends - Extension published

However, the Authority invites those taxpayers who already use version 4.0 to continue to do so, issuing this type of receipt with the aim of familiarizing themselves with the new scheme and implementation of the new requirements it involves.

On the other hand, the Authority also invites taxpayers to keep their tax information up-to-date, as shown on the Certification of Tax Position (CIF), and which includes the following data: 

• Name or company/trade name
• Federal Taxpayers’ Registration number (RFC)
• Tax regime
• Status in the RFC list
• Tax residence (zip code, street, street number, apartment/office number, among others)
• Status of the residence and of the taxpayer
• Economic Activity
• Means of contact
• Fiscal obligations

In virtue of the above and as taxpayers are responsible for updating and checking their tax information, the SAT also reported that employees may provide and confirm the aforementioned information to their employer without the need to provide the corresponding CIF.

It should be pointed out that in the case that employees do not supply their CIF to their employer, this will not be grounds for dismissal or the refusal to pat the corresponding wages and salaries to the employees, taking into account the fact that the issuance of the tax receipt (CFDI), which has repercussions in terms of tax deductibility and crediting in the case of not meeting the corresponding requirements, is independent from the fulfillment of the labor obligations that the employer has with its employees.

- - - - - - - - - - - - - - - 

As of July 1st 2022, the period of coexistence for taxpayers on the changes of electronic invoicing 4.0 will be finalized, thanks to the fact that as of January 1st of the same year, such modifications came into effect.

Derived from the 2022 Tax Reform, as well as the 2022 Annual Temporary Tax Regulations, published in the Federal Official Gazette last December 27, 2021, changes were made to the electronic invoicing scheme, with the unveiling of the new version 4.0 of the tax receipt, 2.0 of the receipt of payments complement and 1.2 of the payroll receipt, which came into effect on January 1, 2022. However, the Tax Authorities provided a period of coexistence of previous and new regulations for taxpayers, which, according to the second amendment to the 2022 Annual Temporary Tax Regulations, ends on June 30, 2022, and consequently the use of these documents is mandatory as of July 1, 2022. 

It should be pointed out that in the case of failing to comply with these obligations, such documents will not have the corresponding tax effects for tax deduction and crediting purposes. Along these lines, these new versions establish changes and new requirements for the proper issuance of invoices, including the following:

Digital Tax Receipt 4.0

• Mandatorily includes the full name and tax residence of the issuer and receiver.
• Under the heading “Tax Regime”, the valid code of the tax regime of the taxpayer in whose favor the Online Digital Tax Receipt (CFDI) is issued must be provided.
• Under the “Exportation” heading, new fields and catalogs are included to indicate whether the issued CFDI corresponds to the exportation of goods.
• Under the heading “Subject to Tax”, the corresponding code must be provided to indicate whether the business transaction is subject to tax or not.
• For the effects of the CFDIs issued to the general public, the information corresponding to the issuer must be validated and additional data provided when a CFDI is issued on behalf of a third party.
• For the effects of the CFDI usage code, when tax receipts are issued to an overseas resident, the “Without Tax Effects” code must be included; additionally, “Without Tax Obligations” must be used under the “Tax Regime of the Receiver” heading.

Receipt of Payments Complements 2.0

• Information about the transferred and withheld taxes for each received payment must be included.
• In the related document section, it is necessary to indicate whether the original document is subject to tax or not, as well as information about the transferred and withheld taxes of the original CFDI.
• It will be possible to identify payments on behalf of third parties.

Payroll Digital Tax Receipt 1.2

• The full name of the employee must be indicated (first name(s), paternal surname and maternal surname).
• The valid zip code of the employee must be indicated, which must coincide with the tax residence registered with the Tax Administration Service (SAT) and which can be confirmed by means of the Certification of Tax Position (CIF).
• The tax receipt of the worker must be inserted, which should be under the code “605” “Wages and Salaries and Income Equivalent to Salaries”.
• The code “01” (“Payroll”) must be included under the use of the CFDI.
• The code “01” (“Not subject”) must be included in the field “Subject to the Tax”.
• Validations of the method of payment are eliminated.
• It is mandatory for the issuer of the receipt to include their full name or trade/company name, valid zip code and tax regime.  

It is also important to mention that an extension has been issued for the issuance of CFDIs with the Waybill Complement to September 30, 2022.

As can be seen from the above, the corresponding analysis and changes will have to be carried out in order to be able to meet these new requirements so as to prevent any fiscal contingency. At Mazars we are at your disposal to help you with any doubt or concern you may have to this regard.