IMPORTANT STEPS TO PROTECT YOUR DEDUCTIONS AND YOUR DIGITAL STAMP CERTIFICATE

January 2026

The Ruler 2.9.18. of the Miscellaneous Tax Resolution (2026) RMF establishes the procedure so that the natural and legal persons who gave tax effects to the Digital Tax Receipts over the Internet (CFDI) issued by taxpayers included in the definitive list of the article 69‑B of the Federal Tax Code (CFF) credit the materiality of operations or correct their tax situation, according to the procedure sheet 83/CFF^[1].

The rule is derived from penultimate paragraph of article 69‑B of the CFF, which expressly recognizes the possibility that third parties affected by the inclusion of an issuer in the definitive list can prove that they actually acquired the goods or received the services covered by the CFDI..

The penultimate paragraph of article 69-B contemplates two alternative ways to restore tax effects:

1. Accredit materiality: document that the goods were acquired or the services covered by the rights were received. (CFDI), and “key” executive: contracts, payment vouchers, delivery minutes/receipts, emails, photographs, minutes.
2. Submit complementary statements: correct the corresponding tax returns to adjust deductions, accreditations or tax bases.

The Rule 2.9.18 of the RMF and File 83/CFF establish the procedure and deadlines to prove the materiality of the CFDI or to correct the tax situation.

• Presentation location:
  • Office of Parties of the Deconcentrated Administration of Tax Audit that corresponds to the tax domicile.
  • in your case, in the General Administration of Large Taxpayers.
  • in your case, before the Central Administration of Strategic Control.
• Requisitos:

Free writing in original and two copies, that contains the requirements provided for in the articles 18 Y 19 Del CFF, in which reference is made to:

• List of tax receipts and documentary and informative support that proves the completion of the operations covered by the CFDI.
• in your case, the complementary declaration through which the tax situation was corrected.
• Deadline to submit: 30 days counted from the publication of the list (taxpayers in 69-B) in DOF, to submit the report and documentation in accordance with File 83/CFF.
• Additional requirement: The authority may request information; the taxpayer has 10 business days from the business day following the notification to respond.
• Magnification: the term of 10 days can be extended 10 more days if requested within the initial period.
• Resolution: The authority has a maximum period of 30 days to resolve counted from the presentation of the request or from the moment the requirement is considered fulfilled.
• Valuation: if the information provided is insufficient or not presented, The authority will evaluate only the available evidence and will resolve in accordance with the law..

[1] 83/CFF Report and documentation that must be presented by the taxpayers referred to in the rule 2.9.18. to prove that they actually received the services or acquired the goods covered by the tax receipts that were issued to them or that their tax situation was corrected, contained in the Annex 2.

The consequences for not clarifying: if the materiality is not proven nor the declarations are corrected within thirty days following the publication of the list of taxpayers of 69-B, the authority may: (1) leave VAT deductions and crediting without tax effects; (2) impose sanctions; Y (3) temporary restriction of Digital Stamp Certificates.

Suggestion: do not wait for the publication of a supplier on the article 69-B list to react. Implement robust internal controls now (operational, legal, accounting and tax) in order to avoid having to rebuild tests from scratch in case of clarification.

Practical controls to implement immediately

• Registration and traceability: link each CFDI with contract, purchase order, referral guide and proof of payment.
• Reception and validation: minutes or proof of receipt signed by the counterparty; photos and logs when applicable.
• Ordered digital file: PDF/XML and annexes indexed by UUID, date and supplier; backups and access control.
• Periodic review: monthly supplier reconciliations and documentation sampling.
• Responsible and protocols: assign internal managers for compiling evidence and for submitting form 83/CFF if necessary.

DFK MEXICO – FISCAL COMMITTEE