December 1 is the date set for mandatory changes to the CFDI for this year. In parallel, use of CFDI version 3.3 and the new Electronic Payment Receipt (before called Payment Receipt Complement) tax schema also begins. Taxpayers now have just over two months to take the appropriate steps and carry out the technological adjustments to comply with this fiscal reform.
It is important to note that adoption of this complement involves two obligations for issuers. First, they need to generate the CFDI with Electronic Payment Receipt in cases where it is necessary. Second, the issuer is required to make this document available to the recipient. To deal with this, EDICOM has several solutions available:
- We offer the possibility of implementing a storage and publishing portal where, in addition to storing the CFDIs with Electronic Payment Receipt, you can make them available to all of your customers through a public web access where they can run an easy search based on their invoice details.
- Clients already using our Business@Mail e-document publication or EDI sending service via EdicomNet can use the same channel to send the CFDI with the add-on.
When is use of the Electronic Payment Receipt compulsory?
Using the add-on will be mandatory in either of these two cases:
- When the transaction is paid in instalments. In this case, taxpayers must issue an electronic invoice for the total amount of the product or service. They will then need to issue a CFDI with this complement for each instalment payment received. These receipts may be generated up to the 10th day of the month following the date payment was made.
- When a one-off payment is made, but not covered at the time the CFDI is issued. This scenario includes credit transactions fully liquidated after having issued the corresponding receipt (invoice).
Deadline for issuing CFDI with Electronic Payment Receipt
The latest date for reception of the CFDI with payment receipt add-on is the tenth calendar day of the month following the month in which the payment was received.
How the Complement works when receiving several payments
In an invoice that is issued for the receipt of one or more payments, a CFDI with complement may be issued to list all the payments received and generate the related document to include the UUIDs of the invoices linked with said payments, as long as they are all for the same recipient.
Cancelling CFDI with Electronic Payment Receipt
A CFDI may be cancelled as long as it is replaced by another with the correct details and when they are made no later than 10 days of the next month in which the CFDI was issued.
Why was the payment receipt complement created?
By implementing this new add-on, the SAT intends to resolve several problems it has detected. One of these issues is the undue cancellation of invoices by suppliers.
The SAT had been alerted that some suppliers cancelled invoices that had already been paid, which did not allow taxpayers to deduct the corresponding taxes. However, once the payment receipt complement starts being used, a record shall be kept of whether transactions have been settled or not. This leads us to think that some businesses will start using it voluntarily as a legal guarantee.
Another problem tackled by the SAT with this CFDI attachment will be false duplicities of income which were occurring in payments by instalment. In addition, as it will be known which e-invoices have been paid and which have not, delinquent customers will not be able to deduct the expense.
The SAT has published a document with frequently asked questions about the complement which you can consult here.