In a recent article, I discussed the concept of eSocial in Brazil – a new real-time integration requirement that will be focused on payroll taxes among other human resource issues. Well, Mexico actually has beaten Brazil to the market with the requirement of Electronic Payroll Receipts as of January 1, 2014. In Brazil, eSocial will take affect toward the middle of 2014. So as discussed before, Latin American compliance is much more than account payables or ebilling, and the expansion into the Human Resource area is one of many steps. Compliance in Brazil and Mexico now spans:
- Account Receivables
- Outbound Shipping
- Use of 3rd Party Logistics Providers
- Account Payables
- Tax Compliance and Audit Risk
- And as of 2014 – Human Resources through mandates applied to Payroll
So here is the quick and dirty on Nomina Electronica:
- Any domestic Mexico entity with an RFC that is paying employees a wage/salary should be issuing electronic payroll receipts
- Technically, you should have already implemented the process as January 1, 2014 was the original deadline.
- You still need your FIEL, your digital signature and the registration process with the government by utilizing a 3rd party provider. As always, you want a multi-PAC provider as a single PAC is a point of failure and risk to your operations
- There are published “complemento” by the SAT
- There is an “Addenda” concept where companies can place non-government required information
- You can print out the receipts in formats specific to your business
- Payroll deductions are retroactive – meaning that unlike the 72 hour rule for VAT invoices, they can be signed later, but you can’t deduct the taxes until they are CFDI compliant. For example, if you go live March 31st with a fully integrated Nomina process – you can take the payroll from January 1st to March 30th and apply the CFDI registration and then and only then would you truly be able to deduct the taxes.
For global companies, you need to take a regional outlook when approaching Latin America compliance – the legislation is continuing to expand across business processes and you don’t want to end up with 5 different vendors across multiple countries – this will only stress your support teams, your ERP competency center, and your teams responsible for the constant change management. Look for vendors that are able to cover compliance across multiple countries, able to deeply integrate with your ERP system, capable of providing enterprise support in multiple languages, and most importantly guarantee the change management so you are not faced with upgrade projects every year.
