The Second Resolution on Amendments to the Omnibus Tax Bill, published in the DOF last May 6, announces a change in the CFDI schema which will affect the “Payment Method” attribute, which is used to enter in the CFDI how the payment of the operation was performed.
Subsequently, on June 3 SAT published on its website the payment methods catalogue necessary for implementation of this change.
So, invoice issuers must now make a change in their management or e-billing systems so that from July 15 on, the payment method field is aligned with the catalogue defined by the tax authority. Until now, it was regulated as a free text field, so that taxpayers could include the text they considered appropriate to provide this tax information in the corresponding node of the XML file. However, as of next month, they will be required to use the new payment methods catalogue to do so.
This measure from the Tax Administration Service (SAT) will enable the tax agency to include automatic control and validation mechanisms for this information, for example to carry out electronic audits. A code has now been set for each different payment method, as shown in the table below:
Electronic funds transfer
Food stamps or vouchers
From July 15, CFDIs not included among these codes must be stamped by the PAC (CFDI Certification Provider). However, they will not be in full compliance with current regulations, leaving them vulnerable to any audit process. In other words, all taxpayers will be obliged to employ either these numbers or the expression NA (Not Applicable). Nevertheless, this latter option is not the most advisable, as it may entail an audit by the SAT in which, if it is shown that the payment method was known, the taxpayer will be required to rectify and may even face some kind of penalty.
How to adapt to the new payment methods catalogue?
The EDICOM team has been working to update the CFDI platform to include this new development in the CFDI generation system. It is important to bear in mind that the quality of the data contained in the CFDI XML is the direct responsibility of the taxpayer issuing it. In this regard, it is necessary to approach each case with a dedicated focus, to ensure at all times that as of 15th of July, any CFDI submitted through our services will be 100% aligned with the development set forth in the regulation.
For this reason, we strongly recommend that you contact your commercial consultant as soon as possible to find out how to become aligned with this development of the CFDI schema proposed by the SAT.
The CFDI, in time of change
In recent months, the SAT has been rolling out some amendments affecting the CFDI, for example the new foreign trade complement, the INE complement or this catalogue of payment methods. However, the changes are not isolated, as plans are in place to undertake a full update of the CFDI schema in 2017.
Version 3.3, which we shall be seeing soon, already includes some changes in Annex 20 of the Omnibus Tax Resolution. Among them is the plan to create a payroll document independently from e-invoicing, the inclusion of some fields in the XML and the removal of others, thus achieving simplification in billing structure and processes, such as elimination of the fields linked with the fiscal address of the invoice recipient.