The Mexican tax authority has set a grace period during which CFDI 3.3 and CFDI 4.0 can coexist to let companies adjust to these new regulations. First it was expected that this grace period would end on 31 December, 2022.
However, with the postponement of the launch date of CFDI 4.0 (initially planned for 1 January, 2023), this grace period was also delayed until 31 March, 2023.
Main changes to the CFDI system
The changes in the new CFDI 4.0 update are not as drastic as the previous changes in the 3.3 update. The changes are “added” to the already existing requirements of CFDI 3.3. The most important changes introduced are:
- The e-Invoice needs to include the SAT-validated name and address of both the issuer and the receiver.
- It will be required to indicate if the e-Invoice is objected to VAT or not (objeto de impuesto).
- A new usage code (tipo de relación) must be issued since the old one is no longer available.
- The usage of the documents (Uso de comprobantes) list got an update.
- The e-Invoice will need to indicate the Tax regime (Régimen Fiscal) of both the issuer and the receiver.
- eInvoices covering withholding tax will now be able to be linked with its corresponding eInvoice.
New conditions for the cancellation of CFDI’s
In the new CFDI 4.0 update, the cancellation of e-Invoices will have to be done more thorough.
- The cancellation will now have to be justified and documented.
- The cancellation must include one of the service response codes.
- An e-Invoice can only be cancelled in the year in which it was issued.
The fines for not cancelling an e-Invoice properly with the requirements mentioned above can range between 5% and 10% of the total amount of the tax receipt.
New version of the complemento de Pagos
The payment receipt complement (complemento de Pagos), which needs to be issued when payment for an e-Invoice is received, has been updated:
- The complemento de Pagos needs to indicate whether the payment is subjected to tax or not.
- It includes a summary of the total amounts of the payment and taxes which are paid.
- The complemento de Pagos can only be used with CFDI type “P”.
Complemento Carta Porte
Complemento Carta Porte (transportation complement) is a digital tax document in addition to the Transfer CFDI (CFDI Traslado) or also known as eDelivery. The creation of this transportation complement is mandatory when shipping goods in Mexico. If the goods are being shipped by the owner, then the owner has the responsibility to create this digital tax document. However, if the owner of the goods contracts an external transportation company for the transfer of the goods, then the owner could send the relevant information to the carrier, which subsequently will create the digital tax document. The purpose of this document is to generate information related to the goods being transported, such as:
- Way of transportation
- Goods
- Routes
- Destination
Since April 1, 2024 Complemento Carta Porte has a new version called Carta Porte 3.0. This updated version to the Carta Porte 2.0 includes enhanced regulations and stricter enforcement to reduce tax evasion and create more supply chain transparency.
The SAP solution and how PIKON can help you comply with CFDI 4.0
In April 2022, SAP released its solution for the new CFDI 4.0 update. Meaning that your current CFDI 3.3 solution can be implemented next to the new update.
At PIKON, we have set up a Competence Center for Legal Requirements. Here our consultants investigate legal requirements worldwide and their impact on the SAP system. Our team consists of experts that combine in-depth knowledge and the gathered experience. Through our SAP Document & Reporting Compliance (SAP DRC) projects in Mexico, the topic of CFDI 4.0 came onto our radar.
We are a strategic partner who offers clients the best suitable solution to ensure that their SAP system and business processes meet different country-specific legal requirements in the long run. Furthermore, we follow up regularly on new and changing legal requirements relevant to our clients and inform them when action is needed. That way, clients can concentrate on their daily business without worrying about non-compliance with necessary regulations.