New - 02/24/22
No. 88/2022 Circular AMEXIPAC
Subject: Communication General Directors AMEXIPAC.
We have received multiple requests for information from associates regarding how to treat
the requests of the clients to be able to offer a service of consultation of the name and postal code
prior to the issuance of the CFDI.
These have been with scopes that go from only answering a request for confirmation of name and
CP with a success or failure, until you can return the correct name and CP, like some PACs that don't
belong to this association are improperly offering.
In this regard, and after consulting the members of the regulatory, technical and
legal documents of the Association, in addition to the email sent by the SAT in which it is mentioned:
“… the information contained in the LCO and the LRFC is provided solely for the purpose of
that they comply with the validations established in Annexes 20 and 29 of the current RMF; any use
other than the aforementioned could constitute a breach of the commitment to confidentiality, reserve
and protection of information and data,…”
There is a consensus that it is absolutely forbidden to offer any service other than that of
validation during the stamping process.
We understand that it is an operational need for customers to be able to validate this information to
be able to carry out smooth and continuous invoicing, but our interpretation is that the objective
is to guarantee that the tax data provided are requested directly from the SAT, for which
there are various means such as those specified in the statement of February 13 of the SAT that
Mention the following links:
Links to check your tax data:
- https://www.sat.gob.mx/aplicacion/login/53027/genera-tu-constancia-de-situacion-fiscal
- http://www.sat.gob.mx/aplicacion/login/28889/obten-tu-cedula-de-Identificacion-fiscal
For this reason we are sharing the criteria of the members of the different committees to clarify and confirm the interpretation of these questions.
The conclusion is that it is strictly prohibited to give a name and code consultation service
prior to a request for the invoice itself and in that case, as in other
validations, you should only respond successfully to the information provided or error if it is not
find the same information in the corresponding lists.
In case there is any modification that is proposed by the authority, we will let you know
immediate.
As SAT assistants, we must punctually respect the legal regulations to maintain and
individually take care of the authorization title issued by the tax authority.
Receive a warm greeting.
Sincerelly,
AMEXIPAC, A.C.
See: Comunicado AMEXIPAC.