The amended guidance provides new deadlines and details concerning this new requirement.
Overview of electronic accounting rules
In general, taxpayers must file their accounting information through a new “taxpayer mailbox system.” Only when the taxpayer does not have internet access or if the size of the files does not fit the taxpayer’s mailbox system capabilities can the information be filed directly in the tax administration’s offices.
Accounting information to be filed with the Mexican tax administration includes:
- The chart of accounts (catálogo de cuentas)
- Monthly trial balances (balanzas de comprobación)
The chart of accounts must be filed with the taxpayer’s first filing and then each time the filing is modified. The trial balances are to be filed on a monthly basis and must reflect the transfers / transactions for the month as well as the opening and closing balances.
The accounting records are to be kept in an electronic system capable of producing XML format files. The Mexican tax administration may request that the taxpayers provide their book entries, and such book entries must include details of the transactions, the book accounts and subaccounts, a reference to the electronic invoice, the tax rate applicable to the transaction, as well as the tax identification number of the third parties involved in the transactions.
Moreover, the electronic accounting records must comply with all the new requirements set forth in the new regulations to the federal tax code.
The published guidelines provide a list of grouping codes that must be added into the trial balance in order to group the book accounts in a standardized format, so as to facilitate review by the tax administration.
The guidelines provide that Mexican entities must file their electronic accounting records beginning with the one for July 2014.
The electronic filing requirement for individuals will start in January 2015.
The trial balances are to be filed on a monthly basis, on or before the 25th day of the following month.
However, the amendment guidelines (Spanish), as posted in August 2014 on the tax administration’s website, indicate that the chart of accounts and the trial balances for July-December 2014 are to be filed in January 2015.
Read an August 2014 report prepared by the KPMG member firm in Mexico: Electronic accounting
Along with the Mexican tax reform for 2014, the Mexican Congress made several amendments to the tax law, one of which relates to accounting records for tax purposes.
Mexican taxpayers are required to maintain electronic accounting books and records and file them on a monthly basis with the tax administration.
In line with these new obligations for taxpayers, the tax administration issued regulations (published in the official gazette in February 2014) that provide additional guidance and requirements concerning accounting books and records for tax purposes. According to the tax regulations, accounting books and records for tax purposes must include:
- Accounting records, including the list of accounts and the vouchers or proof of payments of such records
- All notices filed with the tax administration concerning the taxpayers’ taxpayer identification (ID) including tax residency modifications, enrollment of branches, modifications to tax obligations, etc.
- All tax returns including annual returns, estimated returns, information returns, and any other additional return
- Bank statements and bank reconciliations, including statements relating to investments, credit cards, debit and electronic purses for fuel or food payment granted to the taxpayer’s employees
- Shares, equity interest, and any other negotiable instrument in which the taxpayer is a party
- Documentation related to the hiring of employees as well as notices and enrollments before the tax administration and social security concerning employment status
- Documentation related to imports and exports of goods
- Documentation and records of all transactions, events or activities that are to be registered in accordance with the internal control system
The tax regulations also provide a detailed explanation as to how taxpayer electronic accounting records are to appear. These include that the accounting books and records:
- Are to be analytical and made in the month in which the transactions, acts or activities are carried out, at the latest within five days of completion of the transaction, event or activity
- Are to integrate into the journal, in a descriptive manner, all operations, actions or activities in the chronological order in which they were made, indicating a charge or credit and the name of the accounting account, with the journal also showing the opening balance, transactions for the period and the closing balance
- Are to provide sufficient information to allow for the identification of each transaction, act or activity with a number assigned to the electronic invoice or the corresponding support documentation, so that the payment and the tax rate for each transaction may be identified
- Are to allow for identification of fixed assets and capitalized amounts with electronic invoices or corresponding support documentation, so that the acquisition date, the asset description, the original purchase price, the depreciation rate, and the start date for depreciation can be identified
- Are to include financial statements—i.e., the balance sheet, income statement, statement of change in stockholders’ equity, and the cash flow statement as well as the trial balance and notes to the financial statements
- Are to be maintained in the Spanish language and amounts designated in Mexican pesos
- Are to be established by cost centers, and identify the transactions, acts or activities of each branch or establishment, including those that are located abroad
- Are to include the date of completion of each transaction, the description, the quantity, the method of payment and if the payment was made in installments (or not)
- Are to allow for identification of deposits and withdrawals from bank accounts opened by the taxpayer and for reconciliation of bank statements
- Are to include an inventory records of goods, raw materials and goods in process, so as to allow for the identification of the quantity, type, date of purchase and sale, as well as the increase or decrease of inventory and stock at the beginning and end of each month and at the end of the fiscal year, specifying the date of delivery or receipt, as well as whether it is a refund, donation or destruction, if applicable
- Are to include records relating to the deferral option for leasing contracts, and to allow for identification of such operations of each fiscal year
- Are to include the value added tax (VAT) that has been transferred to the taxpayer as well as the VAT paid on the importation of goods, by dividing the expenses into three categories—(1) exclusively related to taxable activities; (2) exclusively related to non-taxable activities, and (3) related to taxable and non-taxable activities
For more information, contact a tax professional with KPMG’s Mexico tax center:
Jose Manuel Ramírez
+1 212 872 6541