Flash: Fiscal electronic invoices

Versión en español

When does version 4.0 for electronic invoices issuance will be enforced?

What are the modifications introduced by this new version?

On February 18th, 2022, the Mexican Tax Administration Service published the second preliminary modifications to the Mexican Administrative Tax Regulations, which provides an extension regarding the mandatory issuance of electronic invoices (CFDI) employing the 4.0 version. 

Extension

The Administrative Tax Regulations extends the co-existent period of versions 3.3 and 4.0 of the electronic invoices up to June 30th, 2022. This modification will come into force after its publication on the Mexican Official Gazette in the following days. After June 30th, 2022, all the electronic invoices issued by Mexican taxpayers shall comply with the 4.0 version provisions. This extension period also applies to the introduction of version 2.0 of withholding and payment information CFDI.

Version 3.3 was enforced on 2017 and became the standard regarding the issuance of electronic tax documents. Version 4.0 was enacted on January 1st, 2022 and maintain several of the requirements established for the 3.3 version, but it also introduces some others as:

• Changes in the cancelation methodology
• Inclusion of export information
• Possibility to register more than one related invoice, among others
   

In the electronic invoices corresponding to the payroll, the employers must validate the information that is incorporated, among which is: federal taxpayer registration (RFC, per its acronym in Spanish), name, fiscal regime and postal code of the worker (recipient).

Compliance with the new electronic invoicing requirements represents a relevant change to all taxpayers, as it is a multidisciplinary labor that comprehends resources from the operative, administrative, tax, technology, and financing teams. It is important to bear in mind that lack of compliance with the electronic invoicing provision could lead to strong sanctions and penalties.  

Entities must identify their current state, evaluate their e-invoicing process, including the quality and quantity of their customers data, technology, and personnel, to mitigate any potential tax exposure.

We remind you that the Partners and lawyers of the Firm's Corporate Legal Practice are more than willing to work together with you to support you in analyzing the impact of this criterion on your company's operations, as well as in any regularization activity.