During 2017, Mexico made several changes to its eInvoicing framework. In addition to the implementation of CFDI version 3.3, modifications have been made to article 29 A of the Tax Code designed to stop the practice of suppliers unilaterally cancelling CFDIs. This process is being replaced with a bilateral process in which the buyer must also be involved.
In short, the new process means that a supplier must first issue a CFDI cancellation request using either the tax authority’s portal (which is a manual process) or through a web service integration provided by a CFDI Certification Provider. The buyer will receive notification that the supplier wishes to cancel the CFDI and will then have a period of 72 hours to either accept or reject the cancellation request. Any lack of response is considered as acceptance. Some exceptions to this general process do however apply (e.g.: CFDIs for an amount of less than 5.000 Mexican Pesos).
This new process was originally scheduled to become mandatory from July 2018, a date which was then postponed to September 2018. Due to complaints from different stakeholders in the eInvoicing market in Mexico and considering the technological and administrative burdens on taxpayers to adapt to the new framework, on Friday, August 31, the Mexican tax authority SAT announced a further extension to the deadline. The date to to start using the new cancellation process will now be November 1, 2018.
Francisco de la Colina is a lawyer working on the regulatory team at Sovos TrustWeaver.
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