SAT Extends Deadline for CCP Implementation Amid Challenges

Mexico’s Tax Administration Service (SAT) has once again extended the grace period for the mandatory implementation of the “Complemento Carta Porte” (Bill of Lading Supplement). The new deadline is now set for Jan. 1, 2024, marking the sixth extension since its original implementation on Aug. 1, 2023. The extension comes in response to a request from Miguel Ángel Martínez Millan, President, National Chamber of Freight Transport (CANACAR), who highlighted that many small and medium-sized businesses lacked administrative infrastructure to comply with the requirements.

According to a statement by SAT, 94,000 taxpayers have been issued a CFDI with the Complemento Carta Porte since its inception in 2022. However, the Mexican Institute of Public Accountants (IMCP) and CANACAR stated that only large taxpayers or entities with sufficient resources, including infrastructure, income, human resources and the support of business chambers, have complied with this supplement. Consequently, many owner-operators are now investing in private digital platforms, reducing their profits in the process.

The IMCP also said that according to CANACAR’s data, 85% of merchandise carriers are small and medium-sized taxpayers that lack the necessary means to fully comply with the Complemento Carta Porte. Moreover, the number of requirements for filling out the supplement has increased from 20 to 71, needling cost adaptations in systems, human resources and technology.

To address these challenges, the IMCP suggested extending the grace period for fines, which has already been granted, and creating an app or other facilities that would enable carriers to generate the supplement more efficiently. The proposal also includes guiding micro, small and medium-sized companies’ carriers and their administrative personnel to alleviate the burden of implementation costs and prevent small businesses from exiting the market due to cost disadvantages.

Not all authorities can verify the CFDI with the Complemento Carta Porte or impose fines. Those who do have that authority include the National Guard, SICT sanitary authorities and SAT, while local authorities lack such powers. The penalty for each electronic income or transfer type invoice issued without the Complemento Carta Porte or that contains errors can go between US$23.83 and US$35.75 per invoice. While the fine for not issuing, delivering or making the invoice with the Complemento Carta Porte supplement accessible to their clients can go from US$1,174 to US$6,713. Additionally, SAT could close the carrier’s facility for three to 15 days.

It is crucial for businesses and individuals involved in the transportation of goods within Mexico to be aware of these requirements, since failing to meet them could not only result in financial penalties but also put clients at risk of being accused of tax evasion and having the merchandise seized. Therefore, ensuring compliance with the Complemento Carta Porte regulation is essential to avoid these risks as the Jan. 1  deadline approaches.