You hold an IMMEX program. You temporarily import inputs you will transform and return. And you still pay VAT on every entry.
That isn’t your broker’s mistake. Since 2015, temporary imports trigger VAT — and IEPS where the goods generate it — and the IMMEX program alone doesn’t exempt it. That money comes back later through credit or refund, but in the meantime it is out of your account. In an operation importing every month, that is working capital permanently trapped.
The VAT and IEPS certification exists precisely for that: so you never disburse it.
The three ways out
Facing VAT on temporary imports there are exactly three routes:
1. Pay it and recover it. It works, and requires no prior filing. The cost is time: weeks or months pass between the outlay and the recovery, and that time multiplies across every shipment in the year.
2. Guarantee it. Through a bond or letter of credit in favor of the authority. You don’t disburse the tax, but you pay for the instrument and consume bank credit lines — the same ones you may need for something else.
3. Get certified. You obtain a credit equal to 100 % of the VAT and IEPS the temporary import would trigger. Nothing is paid and nothing is guaranteed: the credit is applied on the entry.
The third suits a recurring operation best, and it is also the only one that requires proving your internal controls are in order.
What the certification actually is
It isn’t a separate program. It is a modality of SAT’s Company Certification Scheme registration. The same registration has other modalities with different purposes:
- VAT and IEPS — the credit this article is about.
- Trading and Importing Company — for buy-and-sell operations.
- Authorized Economic Operator — focused on supply chain security and clearance facilitation, explained in AEO/OEA.
- Certified Trade Partner — for carriers, terminals and brokers.
You can hold several. The VAT and IEPS one is the one that touches cash directly.
The tiers: A, AA and AAA
The modality is granted in tiers, with increasing benefits and validity periods. The base tier grants the credit and a short validity; the higher ones add operational facilitations — extended deadlines, simplified filings, lower inspection incidence — and longer validity, in exchange for stricter track record and control requirements.
The exact periods and requirements per tier live in the General Foreign Trade Rules, which are updated every year. Check the current version before assembling the file: this is the kind of detail that changes without notice and invalidates an entire application.
What SAT really looks at
The formal requirements are published. What’s worth understanding is what the authority is evaluating behind each one:
- An active program and a real operation. That the company actually produces or provides the service the program covers.
- Inventory control per Annex 24. This is the substantive requirement. Without a system tying receipts, issues, balances and per-entry discharges together, certification isn’t possible.
- Tax compliance, yours and third parties’. A positive compliance opinion for the company, its shareholders, and its main suppliers and customers.
- Personnel registered with IMSS. A minimum number of registered workers with contributions up to date.
- No link to the lists of taxpayers with non-existent operations. Neither the company nor those invoicing it.
- Registered, locatable addresses, with the declared infrastructure actually there.
- An on-site inspection. The authority will come see the plant and the system running.
Annex 31: the credit isn’t a stamp, it’s an account
This is where many companies get surprised.
The credit isn’t granted and then forgotten. It is administered in a control account system where each temporary import opens a balance, and that balance is discharged when the goods are returned, change regime or are transferred on time.
If the return doesn’t happen within the deadline, the balance isn’t discharged and becomes an assessable liability. No audit is needed: the system itself makes it visible.
That’s why the certification isn’t lost at the application stage. It is lost in maintenance: discharges never made, deadlines that expire, inventories that stop reconciling against entries. Annex 24 and the credit account are the same problem seen twice.
What it’s worth, in cash
The math is direct. Take your average monthly temporary imports, apply the VAT rate, and multiply by the months your recovery cycle takes.
An illustrative example: an operation temporarily importing the equivalent of USD 500,000 per month generates around USD 80,000 in monthly VAT. If recovery takes three months, roughly USD 240,000 sits permanently immobilized — not as an expense, but as cash you cannot use for anything else.
The figures are an example, but the structure isn’t: substitute your own and the result is usually larger than people estimate from memory. That is what the cost of certifying and maintaining certification gets compared against.
Certification or guarantee
| VAT and IEPS certification | Guarantee (bond or letter of credit) | |
|---|---|---|
| VAT disbursement | No | No |
| Recurring cost | Maintenance and internal audit | Instrument premium or fee |
| Consumes bank credit lines | No | Yes |
| Time to obtain | Months | Weeks |
| Requires solid inventory control | Yes, it’s the core requirement | Less demanding |
| Additional benefits | Yes, by tier | No |
| Risk if something fails | Loss of the registration | The guarantee is called |
The guarantee is the sensible route while you certify, or for an operation that doesn’t yet have the volume or the controls to sustain a registration.
When it isn’t worth it
- Low or occasional volume. If you temporarily import a few times a year, the cost of maintaining certification exceeds the financial benefit.
- Weak inventory control. Certifying with an Annex 24 that doesn’t reconcile is accelerating toward a review with the house in disorder. Fix the control first; apply after.
- Returns that miss their deadlines. If your production cycle routinely exceeds the permitted stay periods, the credit turns into a liability quietly accumulating.
- A trading operation rather than manufacturing. There, a different modality is probably the right fit.
How to arrive prepared
- Audit your Annex 24 first. Reconcile physical inventory against the system and against entries, at least for recent months. Whatever doesn’t reconcile now won’t reconcile before the authority either.
- Check compliance opinions — your own, your shareholders’, and those of your main suppliers and customers. A third party in bad standing sinks the application.
- Clean up the addresses. What is registered must match what physically exists, warehouses and branches included.
- Document the processes, not just the results. The inspection evaluates the system, not a snapshot of inventory.
- Name who maintains the credit account inside the company. Without a person accountable by name, it doesn’t hold.
- Verify the current rules before filing, because tier requirements are adjusted every year.
At TradeWay
We support IMMEX operations through the pre-certification diagnostic — inventory control, entry reconciliation and file review — and we run clearance, transport and bonded warehousing through a single point of contact and a single invoice. If you want to know whether your operation is ready to certify, contact us.
