Amendments to International Trade Rules Bring Changes to the Mexican Certificate Scheme

The "Second Resolution of Amendments to the International Trade Rules for 2024 and to Annexes 1, 2, 5, and 24" was published on Oct. 14, 2024, in the Federal Official Gazette (Diario Oficial de la Federación), introducing several changes to the Mexican Tax Administration Service (Servicio de Administración Tributaria or SAT) Certificate Scheme.

Value-Added Tax (VAT) Certificate: New Annex 24 Requirements

Enterprise Resource Planning (ERP) software will need to be connected to the Inventory Management System (Annex 24). As a result, information uploaded to the ERP system must be transferred to Annex 24 within 48 hours.

Any customs-related information not included in the ERP system must be uploaded to Annex 24 at the same time the import and/or export request is paid.

Companies must provide the authorities with a specific user and password to access Annex 24.

Importers of record have one month to begin complying with the new Annex 24 requirements. Therefore, these new regulations will be enforceable as of Nov. 15, 2024.

VAT Certificate: Compliance Reports

VAT certificate holders may only import and use the materials that have already been authorized by the SAT. If different materials are needed, it is necessary to first notify the SAT before importing the new materials.

VAT Certificate: Application Process

Companies must comply with new requirements and formalities to obtain initial approval, including exporting 80 percent of the sensitive materials imported in the 12 months prior to the application process.

Note that importers of record with a certificate in place must begin complying with the new exporting rate for soon-to-be-filed renewals, as detailed in the below section.

VAT Certificate: Renewal Process

Certificate holders will need to follow a slightly different renewal process due to the newly created form referred to as 153/LA.

Other Amendments

There are other amendments to the SAT Certificate Scheme that need to be reviewed on a case-by-case basis to determine the real impact on the VAT, authorized economic operator (AEO), certified business partner, and import and trading certificates.

Please contact the authors with any questions regarding the new amendments to the international trade rules, the implementation of software solutions and validation. We are prepared to assist you with the implementation process and to identify any additional adjustments that may be necessary.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.