Estrategia Aduanera: Materiality and Traceability in Foreign Trade

The new Electronic Value Declaration (MVE) requires importers to verify the materiality and traceability of foreign trade operations in advance. Baker Tilly highlights the need to align accounting records and contracts with values declared to the SAT to avoid regulatory risks.

Several years ago, we entered the era of operational traceability, and it is now the turn of foreign trade operations. The first signs emerged between 2020 and 2021 with the introduction of comprehensive audits by the SAT (Tax Administration Service).

This new review format implies not only submitting the customs declaration (pedimento) with its annexed documents presented at the time of clearance but also requires documents related to accounting records, proof of payment to suppliers, carriers, insurers, bank statements, and contracts, among others. These documents are precisely what now form an integral part of the Electronic Value Declaration.

We are now discussing the traceability of foreign trade operations, specifically regarding how the customs value of goods is calculated.

Invariably, this new auditing approach has required different areas within a company to interact effectively, ensuring that the costs and expenses comprising the value of goods in accounting records coincide with the values declared in the customs entry.

Specifically, with the imminent implementation of the new Electronic Value Declaration (MVE) format and the requirement to accompany it with supporting documentation for the declared values, it is clear that importers will be providing the authorities with information that was previously part of verification powers. Today, this information is necessary to carry out the importation process. In other words, companies can no longer wait for a formal information request; in every operation, they must effectively prove the contractual relationship and the terms established with each supplier. The materiality and traceability of the operation must be properly integrated in advance of each transaction.

In recent months, we have encountered cases where companies have contracts or commercial agreements with suppliers, or even maquila contracts with related parties from several years ago. Upon reviewing these to ensure they comply with the new MVE regulations, we have identified contracts that no longer reflect the companies' current operations. It is precisely these situations that have led authorities to pay special attention to the correct traceability and materiality of imports and overall corporate operations.