Electronic accounting as an obligation for AEO companies.
As has been pointed out, the figure of the Authorized Economic Operator (AEO) finds its legal basis in article 100-A of the Customs Law, which, in its section II, establishes that companies that aspire to have certification in the modality de authorized economic operator, must be up to date in the fulfillment of their tax obligations.
Along those lines, rule 7.1.1. of the General Rules of Foreign Trade, in its section II, in the same way establishes that it is necessary to comply with tax obligations, in addition to customs obligations.
That is why the provisions of article 28, section IV of the Fiscal Code of the Federation must be observed, which indicates the obligation to enter the ACCOUNTING information on a monthly basis to the SAT Portal, in accordance with the general rules issued for this purpose.
Derived from this, in the Miscellaneous Tax Resolution, in its chapter 2.8. Accounting, Declarations and Notices, Section 2.8.1. General provisions, it is established in rule 2.8.1.5. regarding the accounting of electronic media, which it is necessary to enter in XML format:
- The catalogue of accounts used in the period in question, to which a grouping code of the Tax Administration Service will be added.
This file will serve as a reference with the information contained in the Balance of Verification (account and sub-account) and with this the description will be obtained; it should be specified that the taxpayer must be careful at the time of generating and entering the account catalog to the portal, which must coincide 100% with the information presented with the balance of verification.
Likewise, in Annex 24 of the Miscellaneous Tax Resolution and in its technical document you will find the structure that this catalog of accounts must contain.
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- Regarding the balance of verification, it must reflect as minimum data, the balances of the accounts in order to make it possible to identify the taxes payable or payable, as well as those actually paid and collected, in accordance with the provisions of article 33, section III of the Regulations of the Fiscal Code of the Federation.
In the case of the closing balance, it is necessary to add information related to the adjustments that are recorded for tax purposes.
It should be noted that, for the purposes of presenting this balance of verification in the SAT portal, it is only necessary up to the sub-account at the first level.
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- The policies and auxiliaries of account at the major level or sub-account of first level with the detail with which the accounting records are made.
It is necessary to point out that in these policies and their respective auxiliaries they must contain the folios of the CFDI, form of payment, type, rate and quota of the respective taxes, even of those operations for which the tax should not be paid.
When it comes to operations with third parties, it is necessary to have the Federal Taxpayers Registry.
In the event that it is not possible to identify the folio of the CFDI in the accounting registration policies, the administrative facility is granted that they are registered in an auxiliary report, and must contain as minimum data, all the CFDI folios, the RFC of the client or supplier involved, the moment of the operation.
It should be noted that in the same way, in the aforementioned accounting assistants, it must be possible to identify as minimum data the PAGES OF THE CFDI of each operation.
However, the Regulation or the Fiscal Code of the Federation establishes the minimum requirements that an accounting registration policy must have, such as: be analytical and carry it out in the month in which the operation was carried out, no later than the 5th of that month; it must be integrated into the Journal book; and in each registered operation it must be possible to identify the balances that result in the final figures of the accounts.
To be able to comply with the above, the Miscellaneous Tax Resolution gives us the deadlines by means of which the obliged companies may present their electronic accounting, being the case that:
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- When it is the first time that the catalog of accounts is presented, this must be done at the time of raising the balance of verification, which must be entered in the first three days of the second month after which the declaration of the period to which the balance corresponds must be submitted.
That is, if the balance corresponds to the period of January 2022, the declaration had to be submitted on the 17th of the following month, February 2022, therefore, the balance of verification must be presented on April 3, 2022. obligation
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