CFDI & Pedimento: Reconciling Your Mexican Import Records

For a Mexican import, the pedimento and the later CFDI serve different purposes but can be legally connected. Article 29-A of the Federal Tax Code requires the customs-document number and date on a CFDI for a first-hand sale of imported merchandise. Article 5 of the VAT Law separately makes a pedimento in the taxpayer’s name showing the import-IVA payment one condition for crediting that IVA. Reconciliation is an important control, but matching records alone does not create a tax credit.

Key takeaways

• For a first-hand sale of imported merchandise, Article 29-A requires the CFDI to state the number and date of the relevant customs document.
• When an import is carried out on behalf of a third party, Article 29-A also calls for the customs-document number and date, the amounts paid directly by the taxpayer to the foreign supplier, and the import contributions paid.
• For import IVA crediting, Article 5 says the pedimento must be in the taxpayer’s name and show payment of the corresponding IVA.
• That pedimento rule is one of several credit requirements. Classification of the activity, deductibility, payment and the other current statutory conditions still need tax review.
• A foreign supplier invoice and customs value can differ for documented valuation reasons. Reconcile the records and explain adjustments rather than assuming their totals must be identical.
• This is general information, not tax or accounting advice. Confirm the current CFDI fields and IVA treatment with a Mexican contador or fiscalista.

What are the CFDI and the pedimento?

The CFDI (Comprobante Fiscal Digital por Internet) is Mexico’s digital tax receipt. The pedimento is the customs entry record for the import. The two do not replace each other: one records a tax transaction, while the other records the customs operation.

Their direct connection appears in Article 29-A. When a CFDI documents a first-hand sale of imported merchandise, it must identify the relevant customs document by number and date. The underlying import process is covered in our pedimento and Mexican customs guide.

When must a CFDI identify the customs document?

Article 29-A distinguishes two situations for imported merchandise:

• For a first-hand sale, the CFDI must include the customs-document number and date.
• For an import made on behalf of a third party, the required information also includes the concepts and amounts the taxpayer paid directly to the foreign supplier and the contributions paid on importation.

The statute uses the term documento aduanero. In a normal customs entry this will often be the pedimento, but your invoicing system and accountant should map the exact current CFDI fields to the actual customs operation. Do not turn the first-hand-sale rule into a blanket statement that every later resale always has the same customs-reference requirement.

When may import IVA be credited?

Article 5 of the VAT Law contains cumulative conditions for crediting IVA. For IVA paid on importation, one express condition is that the pedimento be in the taxpayer’s name and show payment of the corresponding IVA.

That means:

• A taxpayer should not assume it can claim import IVA shown on another party’s pedimento.
• The pedimento and proof of the IVA payment must be retained with the accounting support for the claim.
• The other Article 5 requirements and the taxpayer’s specific use of the goods still matter; a clean reconciliation is evidence, not a substitute for those rules.

Ask a Mexican tax professional to determine whether the IVA is creditable in the relevant period and activity. This article does not determine eligibility for a particular taxpayer.

What should be reconciled?

Use reconciliation as an audit trail, not as a claim that every document must carry the same total.

Record	Check	Why
Customs document / pedimento	Importer, number, date, declared value and IVA payment	Supports the customs operation and, where applicable, the Article 5 condition
Foreign supplier invoice	Product, quantity, commercial price and payee	Supports the underlying purchase
Valuation workpapers	Additions, adjustments and exchange-rate treatment	Explains why customs value may differ from invoice price
First-hand-sale CFDI	Required customs-document number and date	Supports the Article 29-A requirement
Accounting and tax workpapers	Inventory movement and basis for the IVA treatment	Connects the records without replacing a statutory tax analysis

If a field, party or amount differs, document the reason and correct genuine errors. A difference is not automatically wrongdoing, and unexplained consistency is not by itself proof that every tax requirement was met.

How does this interact with DDP imports?

Under a DDP proposal, the importer of record may be a named eligible Mexican party rather than the buyer. If the pedimento is not in the buyer’s name, the buyer should not assume that the import IVA on that pedimento is its own credit under Article 5.

Before choosing the structure, confirm the named importer, customs broker, valuation, tax documents, scope and exclusions in writing, shipment by shipment. Then ask the buyer’s contador how the domestic purchase and CFDI should be treated. The commercial terms are compared in DDP vs DAP vs FOB.

Frequently asked questions

Does a CFDI need to include a pedimento number? For a first-hand sale of imported merchandise, Article 29-A requires the number and date of the customs document. Confirm the exact field and document for the operation.

Can I credit the IVA paid at importation? Only if the applicable Article 5 conditions are met. One express condition is a pedimento in the taxpayer’s name showing payment of the corresponding IVA; other conditions also apply.

Must the foreign invoice equal the customs value? Not necessarily. Customs value can incorporate documented valuation elements beyond the commercial invoice price. Reconcile and explain the calculation instead of forcing an unsupported one-to-one equality.

What if another company is the importer of record? Do not assume the IVA on that company’s pedimento is creditable by you. Confirm the purchase documentation and tax treatment with a Mexican tax professional before the shipment.

Get the import side right from the start

We coordinate freight and Mexican clearance through the named eligible importer of record and licensed customs broker; the taxpayer’s contador determines the CFDI and IVA treatment. For a China→Mexico shipment, confirm the parties, product eligibility, pedimento scope, documents and price shipment by shipment on WhatsApp. For the wider process, see our customs and compliance guide and complete guide to shipping from China to Mexico.