With the recent addition of Section C to Annex 24, companies operating under the IMMEX program and those holding VAT and IEPS certification now face a new obligation that goes beyond a technical update—it opens the door to a more aggressive and automated model of electronic audits conducted by AGACE (General Administration of Foreign Trade Audits under SAT).
This new requirement demands companies generate structured reports with greater precision and traceability, aligned with data already held by SAT through the (SCCCyG), and other customs systems. Its implementation facilitates automated data cross-checks, making it significantly easier for authorities to detect inconsistencies or documentation control failures.
Failure to comply with or properly manage Annex 24—especially under the new Section C—can unleash a series of serious tax, customs, and even criminal consequences, including:
- Omission of VAT (0% and 16%) and heavy fines (130% under Customs Law and 55% under the Federal Tax Code).
- Tax credit assessments with interest and surcharges.
- Ineligibility for VAT crediting and undue payments.
- Presumption of domestic sales, triggering income tax as a permanent establishment (PE).
- IMMEX and VAT/IEPS certification cancellation, disrupting operations.
- Operational flow disruptions due to customs clearance obstacles.
- Presumption of smuggling, potentially leading to criminal liability.
- Forfeiture of goods in favor of the federal treasury.
- Unrecognized deductions in SCCC, leading to pending or incorrect balances.
- Inflated balances in global account statements, affecting tax credit management.
In short, a technical or administrative failure in Annex 24 can quickly escalate into a full investigation, including potential asset freezes or operational blocks.
The Mexican tax authority has evolved toward a preventive and reactive digital audit model, leveraging tools such as:
- Automated electronic audits by AGACE.
- CFDI cross-matching with return reports.
- Real-time validation of goods returns.
- Mass review of global account balances.
This occurs in a context where certified companies are already under stricter scrutiny, and any inconsistency may be interpreted as simulation or abuse of fiscal benefits.
In this environment, waiting for an audit is no longer an option. Companies under a certification regime must proactively prepare through:
- Specialized technical audits of Annexes 24 and 30.
- Comprehensive evaluations of key fiscal audit items: legal stay of goods, discrepancies in contributions, and compliance with non-tariff regulations and restrictions.
- Traceability verification between CFDIs, reports, and merchandise returns.
- Simulation of electronic audits and preparation of technical defenses.
Investing in compliance is not just about avoiding penalties—it’s about protecting your operations, certifications, and business continuity.
Section C of Annex 24 is not just another requirement—it marks a turning point in Mexico’s digital audit landscape. With its adoption, tax authorities now have the tools to automatically detect inconsistencies, control errors, and simulated operations, triggering immediate sanctions, certification revocations, and potential criminal consequences.
In this new environment, compliance can no longer be reactive. Today, real protection is preventive, technical, and continuous. Annex 24 control must be viewed as a strategic cornerstone of any tax and customs compliance system, especially as it’s one of the first areas AGACE reviews in electronic or desk audits.
At ST STRATEGO, we’ve developed the 360° Tax and Customs Compliance Model—a comprehensive solution that enables companies to:
- Validate internal controls for Annexes 24 and 30.
- Detect inconsistencies before they escalate.
- Comply with obligations under IMMEX and VAT/IEPS certification.
- Prepare technically and legally for any audit process.
More than an audit, Compliance 360° is a legal-operational risk management tool designed to ensure continuous compliance and protect your company’s strategic benefits.
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