Increase in the administrative burden derived from the new tax receipt version, new cancellation scheme and amendment to the guidelines for electronic accounting
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Increase in the administrative burden derived from the new tax receipt version, new cancellation scheme and amendment to the guidelines for electronic accounting
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Given the entering into effect of the new version for electronic invoicing (v 3.3) and the new invoice cancelation rules, the number of invoices to be issued will increase.

As of December 1st, 2017, taxpayers will have to issue a receipt called “Electronic Payment Receipt” corresponding to all transactions carried out for which payments were made after the invoice was issued. A receipt will have to be issued for each payment received, whether payments were made in installments (more than one payment) or as a deferred payment (single payment).

In addition, when a taxpayer transfers his/her merchandise or goods on its own from one branch to another, an electronic tax receipt for the transfer will have to be issued.

In the case of receipts for down payments and the application thereof, the Authorities grant taxpayers two options: the first is to issue a tax receipt for the income corresponding to the down payment amount, an income receipt for the whole transaction and an expense receipt for the application of the down payment, hence rendering an extra receipt compared to the current practice under version
3.2 for down payments and the application thereof; the second is similar to the current practice as to the number of receipts prepared, that is, an income receipt for the down payment and an income receipt for the total transaction to which the down payment was applied. The additional burden for taxpayers occurs when option 1 is chosen.

Up to December 31st, 2017, taxpayers may directly cancel receipts containing errors, without having to issue an expense receipt to cancel them. With the entering into effect of the new system to cancel receipts, as of January 1st, 2018, taxpayers who want to cancel an income receipt, related to a payment made via Electronic Payment Receipt, will have to issue an expense receipt in order to cancel or correct it, increasing therefore the issuance of receipts.

All of the above affects the preparation of electronic accounting, as the more receipts are issued, the more links need to be made to the electronic ledger entries and greater control for accounting is required, especially when linking payment receipts issued and received.

It is important to mention that the review of the requirements for tax receipts to be deductible for Income Tax purposes (ISR) and creditable in the case of Value Added Tax will be more thorough.

Last, but not least, in January 2017, the Authorities informed through its Exhibit 24 of the 2017 Miscellaneous Tax Resolution of the new guidelines for the preparation of electronic accounting, included in a new version (version 1.3.), including the registry on the income ledgers regarding the method of collection, that is, taxpayers will register the collection method (electronic wire transfer, check, cash, etc.) collection date, payee and information regarding the recipient bank account (recipient) and sender (who makes the payment), among others.

It is important to mention that, as of October 1st, 2017, the Tax Authorities now only receives electronic accounting through its platform under version 1.3 (new version).

Conclusions

New guidelines and requirements for electronic invoicing, new cancellation rules and electronic accounting, will cause companies to incur in additional costs for controls and systems in order to comply with the new tax provisions.

Please contact us if you need any clarification or have any question.

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