Since 2015, the tax authorities formally required the sending of accounting information through electronic sources, including trial balance, chart of accounts, information concerning journal entries and auxiliary ledgers, through amendments published in the Miscellaneous Tax Resolution; the authority has modified the technical requirements and information required in order to fulfill this requirements.
Which are the requirements?
It is necessary to take into consideration that the files contemplated by electronic accounting are the following:
Chart of accounts
It will be reported at the level of general leger and subsidiary accounts, which shall be submitted for the first time when electronic trial balance is delivered and starting from there, only if there is a modification on those accounts reported to the tax authority (SAT –Tax Administration Service) the updated chart of accounts shall be submitted.
On a monthly basis it shall be included the beginning balance, movements for the period and ending balance of each of the accounts. It is important to consider that when the following assumption becomes actual, the informative tax accounts shall be included in the chart of accounts, such as CUCA (Capital Contribution Account) and CUFIN (Net Tax Profit Account), just to mention a few.
Delivery of the monthly trial balance shall be made in general form by all corporations on the specific deadline (no later than the third business day of the second month subsequent to the month the information corresponds to); or for the individual tax payer, the information shall be forwarded on the specific deadline (no later than the fifth business day of the second subsequent month; such obligation may be exempted for those individuals having the facility of using the application known as “my accounts”.
Information concerning journal entries and auxiliary ledgers
The obligation to provide journal entries and auxiliary ledgers shall only be applicable when the tax authority request the accounting information; however, it is important to mention that some of the most important requirements that journal entries must be fulfilling, are the following:
- UUID (or Universally Unique Identifier/Fiscal Folio) of the digital fiscal voucher supporting the transaction; in the case of expenses incurred abroad, it is mandatory to include the foreign invoice number and the tax ID of the foreign tax payer.
- Data related to the payment method: issuing bank, account origination the resources, date of transfer.
- Total amount: corresponds to the total amount on the digital fiscal voucher supporting the transaction (including VAT, as appropriate).
- Payment method
Nowdays, some companies have opted to do their accounting with a foreign accounting system, given its international characteristic; however, it is necessary to take into account that in many cases, the software does not comply with the requirements previously described for purposes of electronic accounting in Mexico, thus, it is recommended prior to considering doing the accounting with these foreign systems, to carefully review how the previously mentioned obligation will be fulfilled.
It is important to mention that, in the event of not providing the electronic accounting files through the SAT´s internet page within the established deadlines, or providing faulty files preventing their reading, or else, not being uploaded in accordance with the general rules, the taypayer would be running the risk of the following consequences, just to mention a few:
- Being subject to a penalty from $5,510.00 to $16,520.00 Mx pesos, for the omitted period
- If carrying out international trade operations, the suspension of the company in the official list of national importers and exporters
- Issuance of a negative compliance opinion
On the other hand, it is necessary to bear in mind that in the last few months, the tax authority is cross-referencing the electronic accounting provided by the taxpayers against the digital fiscal invoices issued and received, for which the authorities have been delivering “invitation letters” in which it is being requested to clarify the inconsistencies detected. While these invitation letters do not generate an obligation per se, the letter does provide the authorities with the necessary elements to identify records or incorrect fiscal folios through which the taxpayer could be subject to a tax payment plus penalties and surcharges.