Tax and Legal Services
April 10, 2015
1
Annex 31 “Credit Accounts and Bonds Control System (SCCCyG) ”
VAT Certification
Initial Balance vs physical inventory
What to do?
In brief
The SCCCyG will manage and monitor the tax credits arising from the transactions subject of VAT
Certification benefits, considering an initial inventory of operations that were imported under
temporary basis, and pending to be returned as of December 31, 2014, as well as those imports carried
out starting from 2015, applying such tax credit benefit.
In detail
We have observed that some companies integrated and reported the initial balance of goods temporarily
imported exclusively with the information available on their physical inventory at December 31, 2014,
while others considered the open balance shown on their Inventory Control System (Annex 24), in both
cases with differences or deviations between such information sources.
For example, let´s think about a scenario under which an initial inventory of 6 million pesos, as reflected
in its physical inventory at the time, regardless that the Annex 24 showed an open balance pending export
of 10 million pesos.
This would imply that all corrective action taken in the future will not be related to an accurate initial
inventory, which in turn could call the attention of the Authority as it will have record of all transactions
carried out daily by the companies (Data Stage).
On the other hand, in the case of companies who integrated and reported their initial inventory with an
open balance of 10 million pesos on Annex 24, while having a physical inventory of only 6 million, the
Customs Authority could monitor the customs destination of the open balance of those goods not
supported with a physical inventory.
In the first scenario where the information in Annex 24 was not considered, may be the case where it
considered balances that had already exceeded length stay in Mexico.
The aforementioned cases would mean submitting inaccurate information to the Customs Authority.
www.pwc.com/mx
Recommendations
It is important to emphasize that the lack of an accurate administration along with a control on VAT
Certification obligations, could have the ultimate consequence of its cancellation and, in the worst of the
cases, even the cancellation of the IMMEX Program.
In view of the above, we invite you to consider your answers to the following questions in aims to evaluate
your current situation and, in its case, elaborate a corrective action plan:
Have you considered correcting the initial inventory information originally
submitted?
How are you going to prove the return abroad of goods that were not declared in
the initial inventory?
Would it be necessary to conduct a process of reconstruction of Annex 24 and based
on what information?
Have you considered conducting a change of regime or regularization of open and
un-reconciled balances?
Have you considered possible Income Tax implications (Maquila regime operation,
etc.) and VAT (crediting, etc.) resulting from subsequent corrections?
What different actions will be carried out to avoid further deviations or errors in
the reports of discharges to be transmitted electronically to the authorities?
Let’s talk!
To discuss in specific detail any information,
please contact any of our Foreign Trade Experts:
Mauricio Hurtado
Mexico
[email protected]
01 (55) 5263-6000
Hector Herrera
Mexico
[email protected]
01 (55) 5263-6110
Ivan Jaso
Mexico
[email protected]
01 (55) 5263-8535
Marco Antonio Reyes
Guadalajara
[email protected]
01 (33) 3648-1041
Oscar Manuel Garza
Monterrey
[email protected]
01 (81) 8152-2055
www.pwc.com/mx/impuestos-servicioslegales
The contents of this document are for informative purposes only and are in no case intended as professional advice or as an aid in decision-making. In
any case, the tax and legal provisions should be consulted, as well as a qualified professional.
© 2015 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity.
Please see www.pwc.com/structure for further details.