Mexico has been one of the most important pioneers in the introduction of e-invoicing and has continued to expand it by introducing further e-requirements. With the CFDI 3.3 rule, active since the 1st of January 2018, Mexico is portraying several e-requirements in a single XML format and with a nearly identical process. This means that the process and XML-schema for e-invoices, e-payment (Complemento de Pago) and the e-delivery (CFDI Traslado or Transfer CFDI) are the same, although they all are generated from a different type of source data. As of the 1st of September, the CFDI Traslado will become mandatory. This means Mexico is tightening the control on the deliveries performed by Mexican companies to avoid corruption and tax evasion.
Mexico is not the first country to make e-delivery mandatory. Countries like Turkey and Hungary have also introduced this together with e-invoicing to increase tax control. In case the term e-delivery is unknown, it is sometimes also known as an E-Waybill.
What is CFDI Traslado and when is it mandatory?
The Transfer CFDI (CFDI Traslado) is a tax document that serves to protect the ownership of goods during transport by land within the national borders or abroad. It is important to not confuse it with the Letter of Carriage (la Carta Porte), which is currently also used to document the transport of goods by a company that provides transportation services.
The next part will describe in which situations the Transfer CFDI (CFDI Traslado) is mandatory.
1. When the owner of the goods is the one who transports them
In this case, a CFDI Traslado with a zero value is created and the type of goods that are transported must be specified. Also, the goods must belong to the owner and cannot be the subject of any sale or purchase.
For the goods to be legally transported nationally, you must specify the object of transportation. Here, you are obliged to choose between the options offered by the CFDI Catalog. Last but not least, the transportation complement (Complemento Carta Porte) must be included.
2. When the owner of the goods contracts an external transportation company
In this second scenario, it is optional for the transportation company to issue a transfer CFDI since the carrier is not proving ownership of the goods but rather stands in for the legal transfer. Nevertheless, the transportation carrier is mandated to issue an e-invoice with the transportation complement (Complemento Carta Porte) in this case.
3. When transporting goods abroad
In this scenario, the CFDI Traslado must be used in combination with the Foreign Trade Supplement (Complemento de Comercio Exterior) when they are A1 definitive export operations.
In a nutshell: the transfer CFDI must be used in a mandatory way to transport private cargo. Its main purpose is to protect the transfer and possession of the goods towards the authorities since it does not have a fiscal character.
What does the CFDI Traslado process look like?
As CFDI Traslado is a part of the CFDI 3.3 regulation. It has a nearly identical process and the same XML schema as the one used for e-invoicing and e-payments.
The CFDI Traslado is created based on information coming from the transportation of goods, often displayed in a document such as a delivery. This delivery information needs to be converted to the CFDI 3.3 XML format filling all required data. The document is to be digitally signed and sent to the Mexican tax authorities (SAT) by a PAC. The PAC is a service provider certified by the SAT for direct communication with the SAT. Only a PAC can send electronic documents to the SAT for approval. After approval (or rejection), the XML is sent back to PAC. Then the sender needs to forward the XML and PDF of the electronic document to their customer.
What are the challenges and how can your ERP system help you solve them?
The high number of documents to be created and managed, together with the strict rules of the Mexican government, will increase the amount of work for your employees. Moreover, it increases the risk for penalties in case of mistakes or non-submission.
Apart from the pressure on the employees, your company must also handle the technical difficulties that come with it. As the number of deliveries in most companies is high, the CFDI Traslado regulation will require a high number of electronic documents to be created in XML format and submitted. Therefore, an automatic solution for the creation of the XML and an interface for submission is a must for most companies.
Furthermore, more and more countries are introducing electronic requirements such as e-invoicing. This means that it is not only a challenge to create and submit the documents for Mexico but also for other countries. This might result in difficulties to keep an overview of which countries introduce which requirements and how these requirements are handled in your company. The more countries are involved, the more need you might have for a worldwide solution.
All of these challenges require your business to properly consider how to make your system compliant today and tomorrow to the CFDI 3.3 regulation, instead of seeing this topic as a burden that needs to be solved asap.
How can SAP help you comply to the rules and tackle the challenges?
In SAP, the CFDI Traslado can be created and forwarded by a solution called “SAP Document Compliance”. This is the same solution that is used to create and send e-invoices and e-payments in Mexico. But it does not only cover all e-requirements in Mexico, it can also cover many more e-invoicing and e-delivery requirements all over the world, such as in Italy and Spain.
The SAP Document Compliance solution for CFDI Traslado in Mexico covers the following situations:
- Delivery of a shipment of goods to a customer
- Transport of a stock of goods from one company code to another
- Transport of a stock of goods from one plant to another within the same company code
As explained before, the process is very similar to the e-invoicing and e-payment processes. In SAP, the process flow of the SAP Document Compliance solution for CFDI Traslado is the following:
- In SAP ERP, the post goods issue of the outbound delivery is posted.
- This automatically triggers an eDocument in the eDocument Cockpit.
- When submitting the eDocument, it is converted into the CFDI 3.3 XML format within SAP ERP and forwarded to SAP CPI (Cloud Platform Integration).
- In SAP CPI, the document is digitally signed and forwarded to the PAC.
- The PAC is responsible for making a first check of the content of the XML and for the forwarding of the document to the Mexican tax authority (SAT).
- The SAT approves or rejects the XML and communicates this feedback to the PAC. For every approval, the SAT provides a UUID which can be seen as a unique approval code.
- The PAC sends the feedback to CPI who forwards it to SAP ERP. The feedback can then be found in the eDocument cockpit.
- The last step is to send the XML and PDF of the e-delivery to the customer. This happens from the SAP ERP system.
As the CFDI Traslado, e-invoicing and e-payment can be solved by the same solution, they are generally implemented altogether.
In case of updates of the CFDI Traslado, SAP will provide OSS notes with the update of the mapping and/or technical components. Together with a couple of settings that might change depending on the update, the solution has been adapted rapidly and most importantly without development.
How can PIKON assist you?
As an SAP consultancy company, we have over 25 years of SAP experience. In the last years, we have combined this experience with knowledge regarding the different legal requirements. We have been able to do so by introducing our Competence Centre for Legal Requirements. Here we investigate and perform research about legal regulations and their SAP solution worldwide.
We have successfully finished several Mexican projects in which we have implemented new company codes in Mexico with all legal regulations that come with it. Various times we also implemented the SAP Document Compliance solutions for Mexico.
Not only do we have a strong focus on Mexico, but we also help companies to implement SAP Document Compliance for several countries such as Italy, Spain, Mexico, Hungary, Turkey, Colombia, Greece and more.
Our Competence Centre enables us to stay up to date on the updates of legal requirements and the SAP solutions. This ensures that we can keep the system of our customers compliant with all regulations.