Mexico – Electronic tax bill of lading: key implications

As of September 30, 2021, a new document known as an electronic tax bill of lading has become mandatory for all companies that transport goods (both imported and domestic) within Mexican territory. Failure to comply with this change in a timely manner will trigger customs and tax implications such as penalties, seizure of the goods, and possible tax deductibility issues.

The electronic tax bill of lading must be attached to the electronic invoice for fiscal purposes for any company transporting goods in Mexican territory. This document calls for a series of additional transportation data, such as:

  • Entry and exit ports declared upon import and export transactions
  • Fiscal and operational address of both the sender and the recipient
  • The total distance traveled from origin to destination
  • Value of the goods transported
  • Unit of measure of the goods transported
  • Authorization number issued by the Mexican Ministry of Communication and Transportation (SCT for its acronym in Spanish)
  • Method of transportation used (air, land, sea, railway).

According to the tax authorities, this change seeks to ensure precision and transparency in the supply chain, a decrease in contraband practices, and overall supervision of the Mexican tax authorities over freight earnings and transportation services.

The obligation to incorporate this new document as part of the electronic invoice applies to those transporting goods, which could be the owner of the goods, companies acting in the capacity of a freight forwarder, and transportation providers. These agents in the supply chain must register either the earnings obtained for the transportation services rendered or the value of the goods transferred accordingly (regardless if national or imported) in the tax authorities’ database.

Compliance challenges may arise with the adoption of this requirement. For instance, ERP systems will require further modifications/updates to comply with the additional data that will be displayed on the attachment to the electronic invoice issued. Small and medium-size transportation enterprises will need to comply with all formal regulations for the vehicles in their respective fleets (Transportation Ministry permits, declaration of all drivers name, license plates, address and Tax ID, etc.)

Observation: This requirement will establish a series of new procedures that will significantly impact freight forwarding companies and the way they do business with their clients. Also, due to the variety of transportation arrangements available in Mexico, there still are possible scenarios that have yet to be clarified by the tax authorities.

A failure to issue the corresponding electronic tax bill of lading, to provide such document to the importer, or to issue the document correctly will trigger a series of sanctions, such as:

  • A fine ranging from $850 to $4,660 USD per incident.
  • Following a second offense identified by the tax authorities, the establishment (i.e., transportation facilities/productive plant) can be closed for a period of three to 15 days.
  • If the electronic invoice issued for transportation services does not contain the electronic tax bill of lading, the invoice will not be valid for income tax deductibility purposes.

Due to the likelihood of increased audits, the penalties that can be triggered by a lack of compliance, possible implications for income tax purposes, and potential seizure of the goods within the transportation chain, taking action in a timely manner is crucial.

Observation: The challenge of implementing the series of necessary changes must be shared by all teams within a company involved in the transportation of goods, including Customs, Tax, IT, and Logistic. Communication and cooperation between productive companies and freight forwarders operating in Mexico will be key to successful implementation of the new requirements.

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