New Requirements for the Automated Inventory Control System

Luis Regalado

1 month ago

Dear Clients and Friends:

On October 14, 2024, the Mexican Tax Administration Service (SAT) published the second resolution of amendments to the General Rules of Foreign Trade for 2024, which, among other things, includes a modification to Annex 24. This first modification to Annex 24 impacts, among others, companies registered under the Company Certification Program, establishing new requirements for the automated inventory control system. The reform will come into effect on October 15, 2024, and will introduce a series of additional obligations for IMMEX companies.

ANNEX 24.- The modification requires that this system electronically receives, within a maximum of 48 hours, the minimum information that the inventory system must contain, as detailed in Section A of Annex 24. This information is divided into three categories: catalogs (taxpayer data, materials, and products), modules (information on imports, materials used, exports, and fixed assets), and reports (on imports, exports, materials used, and balances).

The modification also specifies that the Minimum Information must be sourced from the company’s internal system, and the remaining information must be received no later than the time of paying the corresponding customs declaration (pedimento).

Additionally, companies are required to grant online access to the customs authority to verify compliance with legal provisions, monitor temporarily imported goods, and generate necessary reports.

Finally, with the implementation of the amendment, companies must submit a username and password to the authority to enable access to their automated inventory control system.

COMPANIES’ GOODS CLEARANCE REGISTER (“RDME” for its Spanish acronym) – The requirements for companies applying for registration or renewal in the RDME have been modified to include new aspects regarding:

• Procedure sheet.

• Access restrictions to the RDME in the event of being included in the blacklists (tax losses unduly transferred) of the SAT.

• Periods.

• Import value references.

• Obligation of the representatives of the clearance to be up to date with their tax obligations.

• Compliance visits.

• Obligation to have personnel to carry out the production or service process.

• Compliance with employer-employee obligations.

• Domicile registration, and
• The obligation of the partners or shareholders and legal representatives to be up to date with their tax obligations.

CERTIFIED COMPANIES PROGRAM, VAT AND IEPS MODALITY (CIVA).- Amendments regarding the causes for the issuance of a requirement or cancellation of the CIVA are included.

Regarding the issuance of a requirement, it includes the case of those taxpayers that appear in blacklists (tax losses unduly transferred), those that do not have personnel to develop productive or service processes, and adjusts the deadlines for issuing resolutions after requirements, which is now 6 months.

With regard to cancellation, the non-return of temporarily imported goods in accordance with the established percentages is included as a cause for cancellation, deadlines in the cancellation procedure are adjusted, and supervisory measures in the event of obstructed access are established.

IMMEX companies engaged in manufacturing, transformation, repair, or services must return at least 80% of the total value of temporary imports of inputs made during the validity of their Certification (12 months), which represents an increase from the previously required 60%.

Additionally, companies importing goods under the tariff fractions listed in Annex II of the IMMEX Decree or Annex 28 and applying for the CIVA for the first time, must have operated under the IMMEX Program for the past 12 months and comply with the requirement to return 80% of the total value of temporary imports.

Finally, CIVA cannot be renewed if there is an ongoing cancellation procedure or a pending response to a requirement from the company.

VAT GUARANTEE.- Changes have been implemented in the requirements to apply for the VAT tax guarantee. In addition to providing a revolving bond or letter of credit with a 30-month validity, companies must comply with maintaining electronic accounting, implementing an inventory control system in accordance with Annex 24, and being up to date with their social security obligations, such as registration with the IMSS and the payment of employer-employee contributions.

Tax and Trade

Felipe Mendoza / felipe.mendoza@ecrubio.com

Fernando Holguín / fernando.holguin@ecrubio.com

Luis Delgado / luis.delgado@ecrubio.com

Jaime Ogushi / jaime.ogushi@ecrubio.com

Alejandro Montes / alejandro.montes@ecrubio.com

Arturo J. Bañuelos / arturo.banuelos@ecrubio.com

Carlos Enríquez / carlos.enriquez@ecrubio.com

David Fujii / david.fujii@ecrubio.com

Eduardo David / eduardo.david@ecrubio.com

Edmundo Hernández / edmundo.hernandez@ecrubio.com

Juan Carlos Partida / juan.partida@ecrubio.com