New Obligations of Using Version 3.3. of the Electronic Tax Invoices (CFDI) and the Numeric Code for Products and Services as per Annex 20 of the Miscellaneous Tax Rules for 2017
As of December 1, 2017, taxpayers must use the new version 3.3. of the CFDI.
One of the requirements upon the issuance of the CFDI is the utilization of the catalog of products or services for their classification by using a numeric eight-digit code. The first two digits of the code correspond to the division of the product or service; the first four digits comprise the group of goods or services; while the first six digits correspond to the class; and finally, the full eight digit code corresponds to the specific product or service.
The use of the code is a delicate and complex issue that must be carefully evaluated before making a decision on the numerical code that will be used upon issuance of CFDIs. If a wrong key is assigned, or if the CFDIs are filled out incorrectly, this could derive in the challenging of tax deductions and the possibility of crediting the Value Added Tax. Moreover, an incorrect preparation of the CFDI with an incorrect code of product or service may result in unfavorable labor and social security consequences.
On September 7, the Tax Administration Service (Tax Authority) published on its website an update to Annex 20 of the Miscellaneous Tax Rules for 2017, titled “Guide to fill out the electronic tax invoices or receipts on Internet”. This document was published to guide taxpayer for the better compliance with their tax obligations, taking into account previous questions and concerns from taxpayers to the Tax Authority. However, this guide does not cover all possible questions or concerns, and we would be pleased to assist you or discuss with you the filling our of the CFDIs in an attempt to mitigate any possible negative issue from a tax, labor or social security standpoint.
Considering the particularities of the numeric codes for the identification of the products and services, and the filing requirements for the CFDIs, it is not an easy task to identify the code of every product or service, since the issuer of the CFDI could choose a wrong code or not find one that exactly applies to the product or service that it sells.
Therefore, we would be pleased to answer any questions or comments you may have regarding the use of the codes contained in the catalog or to review your drafts of CFDIs or if you wish, to schedule a working meeting to analyze the products or services to be included in the CFDI's.