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Version 3.3 for the issuance of CFDIs - New challenges and the importance of the Public Accountant

In order for the revenues to adequately cover the actions or activities that are carried out and in order that the expenditures incurred are considered as deductible, with the corresponding effect on the value added tax, taxpayers must comply with various fiscal requirements.

Derived from the accelerated evolution that "the invoice" has suffered in recent years in a computerized environment to become a digital version, the most controversial fiscal requirement is that they must be covered by an Online Tax Digital Receipt (CFDI), which also must meet several requirements and whose number increases as the version of the platform on which they are made changes.

Reforms to the CFDI 2017

With fiscal reforms for 2017, it was envisaged to migrate, once again, the current version of a CFDI (from version 3.2 to 3.3). The use of version 3.3 of the application to issue CFDIs will be mandatory beginning December 2017 (first, it should have been since July 2017), that obeys to the need that the authority had in order to correct and make a "friendlier" version of the one that was going to be replaced.

With the dynamics of updating versions, we have even gone as far as observing the emergence of the "Specialist in CFDIs", a concept that, in general, the Accountant of each taxpayer has had to assume to:

  • Fully comply with the requirements of issuance of a tax receipt.
  • Be able to avoid ostentatious fines and risks by making mistakes in their preparation and design.
  • Duly interpret the information contained in the vouchers by the authorities.

The Role of the Public Accountant

Within the IT dimension in which the CFDI is submerged, the Accountant requires:

  • An electronic accounting system (as comprehensive as possible, rented or owned) that complies with tax regulations, and is kept up to date.
  • Permanent technical support from outside (face-to-face and/or remotely) for consultation of electronic or fiscal aspects; or implemented with its own resources (with the consequent high and also permanent costs).
  • A technological storage structure for XML and PDF files respecting the electronic parameters dictated by the tax authorities (which are complex and that only a specialist engineer is able to master), which will form the electronic accounting of the taxpayer.
  • A computerized scheme that is sufficient, timely and in strict compliance with the applicable rules for sending the CFDIs to the purchasers of goods and services, once they are certified or stamped by an Authorized Certification Provider (PAC). The Accountant must work "shoulder to shoulder" with this representative of the supervisory authority with the invariable objective that the CFDIs keep full certainty regarding the compliance of the electronic requirements of each and every one of the receipts that are issued.
  • Full knowledge and constant fiscal update on the variety of data to be included in each CFDI: type of receipt (Income, Debit, Payroll, etc.), payment form and method, determine whether there is an existing and related CFDI, the code of the product or service, quantity, unit code, description and unit value, among the most common.
  • Ability to locate the product or service codes that will be protected in a CFDI, considering that version 3.3 offers an immense diversity of codes.
  • Decision-making ability without mistake on the type of CFDI that should be issued in any given situation: sale in a single exhibition or in installments, advances, payments on account, refunds, discounts, exports, imports, tax withholdings to nationals or foreigners, salaries, etc., and experience in accounting, tax and technological matters (or coming from third parties) to achieve this objective.
  • The professionalism to control all of the above that undoubtedly reflects new and absorbing tasks to the already compelling responsibilities you have as an Accountant, and to render satisfactory accountability.

Prepayments, as an example

The difficulties of these variants and the complex scheme of payments in installments to be applied with version 3.3, can be exemplified with the Prepayments to Clients that must be covered with several receipts:

  • When receiving the down payment, a CFDI is issued for each prepayment received,
  • Upon receipt of the entire consideration, and
  • A CFDI of expenditures covering the total amount of the prepayment.

The authority also considers that this procedure may vary and only the first CFDI should be issued upon receipt of the prepayment, and a second receipt for the remainder of the consideration (which leaves uncertainty about the correct or incorrect mechanism and is subject to the interpretation of a future visitor of the authority).

Other considerations

The new cancellation procedure of CFDIs will start in 2018, on which the Accountant must be aware of the adjustments that will be announced.

The payment of wages must be supported by a CFDI payroll for each payment and each worker, but no longer as a complement to the CFDI as it was with version 3.2.

Dissemination by the authorities

The new features of the CFDI offered by version 3.3 have been permanently disseminated by the authority, but still many doubts remain; so many that it is expected that in the following weeks adaptations will continue to be made to this platform or even that the beginning of its validity will be delayed (as suggested by the Attorney General for the Taxpayer Defense, PRODECON).

Finally, we can say that despite the constant updating of tax provisions and modern IT platforms with increasingly robust electronic outlets (whose costs are irremediably assumed by taxpayers), the obligation to issue CFDIs is not very understandable Despite the tax authorities' saying in regards to the ease and clarity of such issuance. Consequently, the new tasks of the Accountant should be as accurate as possible.

That is why today the participation of the Accountant is highly appreciable by adapting his professionalism to the tax provisions to take responsibility for the satisfactory compliance of the current IT challenges.

 

 

At Moore Stephens Orozco Medina, SC, we have experts in the field, equipped with the technological tools that allow total transparency for our clients in the issuance of Online Digital Tax Receipts to reflect dully and punctually the operations of their businesses, committing ourselves in assisting in the fulfillment of these fiscal obligations with efficiency.

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