Mexican New Invoicing Obligations are Just Around the Corner

As of September 30, 2021, domestic transportation of goods within Mexico will have to be accompanied by a new tax requirement: the Bill of Lading Complement.

Regardless of whether such goods travel by land, rail, air, or sea, either using a company’s own vehicles or a trucking or transportation company’s, entities sending goods through the country will have to modify their electronic invoices (“CFDI,” as per its acronym in Spanish) to include the requirements established on May 3, 2021, by the Tax Administration Service (“SAT”).

As per the Bill of Lading Complement, requirements to be added in electronic invoices include: (i) type of transportation (national/international), (ii) detailed locations pertaining origin and destination, (iii) travel distance, (iv) relevant domiciles, (v) the quantity and description of the goods, (vi) vehicle identification number, (vii) operator’s name and domicile, and (viii) vehicle’s owner name, among others.

Lack of compliance with aforementioned requirements may trigger penalties, and authorities could also consider that the relevant CFDI is not deductible/creditable for income/value added tax purposes.

A number of practical application issues still linger, i.e. what happens if driver has to change its route due to an accident; if the goods are partially or fully rejected; security concerns regarding use of enhanced CFDI’s data, etc. It is strongly recommended to carry out a case-by-case analysis to identify whether the CFDI with the Bill of Lading Complement shall be included in your company’s operations and, if so, which type of invoice shall be issued.