Delegating a tax return can reduce administrative work, but it leaves a concrete question: what still needs to happen before it is complete? If the accountant sends a reference number while the business owner still needs to pay, they may have different understandings of progress. Agree at the outset on the authorized work, the evidence to be delivered and who will verify each outstanding item.
Work instructions do not replace formal representation
Original Fintax Instagram publication about delegating tax procedures to an accountant.
Hiring an accountant does not, by itself, change the taxpayer's statutory obligations. Mexico's Federal Tax Code, or CFF, regulates the legal effects of advanced electronic signatures, representation before tax authorities and preservation of accounting documentation in Articles 17-D, 19 and 30. Internal task assignments must be distinguished from those legal requirements: CFF, Articles 17-D, 19 and 30.
A work order can clarify who prepares, reviews, submits and pays. It is a recommended operational control, not a claim that the document grants formal representation or authority to sign any tax procedure. When an action requires representation, verify the applicable requirements under Article 19; when it involves an advanced electronic signature, review its effects under Article 17-D: Federal Tax Code.
Scope also matters for SAT authorizations. Its third-party authorization service allows consultation of an opinion; it does not provide universal authority to submit or sign tax procedures. For this specific authorization, retain the acknowledgement of the authorization or removal action: SAT, third-party authorization.
Four stages worth tracking separately
This table proposes internal controls. Legally required evidence depends on the procedure; some procedures do not involve payment or a subsequent decision. Use the stages that apply and document why any stage is not applicable.
| Stage | Evidence to review | What you should not assume |
|---|---|---|
| Preparation | Draft, reporting period and explanation of the amount | That preparation means submission |
| Submission | Acknowledgement identifying the procedure and period | That a reference number proves payment or approval |
| Payment, if applicable | Bank payment evidence linked to the procedure | That filing a return demonstrates payment |
| Response and closure, if applicable | Final response and record of outstanding items addressed | That the first acknowledgement eliminates later follow-up |
Hypothetical example: July submitted, payment outstanding
Assumptions: a business owner commissions a return for July; the accountant prepares and submits it after review; the owner makes the bank payment. Assume the result includes an amount payable. The owner must confirm the applicable amount and due date before authorizing submission.
The accountant sends a reference number, but the owner postpones payment. The correct record is submission awaiting verification against the acknowledgement and payment outstanding, rather than procedure closed. Once the acknowledgement has been reviewed, submission can be marked as verified. Next, request bank payment evidence and check that it relates to that transaction. If a subsequent response is required, it remains a separate outstanding item.
A practical control for each procedure
- Describe the procedure and reporting period. Define the authorized work and which changes require fresh confirmation.
- Assign responsibility for preparation, review, submission and payment. Identify who will follow up on subsequent responses.
- Approve the authorized amount, where applicable, with its explanation. If it changes, request a review before proceeding.
- Request the acknowledgement and compare it with the instructions: taxpayer, procedure and period. Record payment evidence separately.
- Record each outstanding item, its owner and the next agreed review. Close the procedure when the applicable stages have been verified.
As a recordkeeping practice, keep the instructions, approved draft, acknowledgement, payment evidence and final response together where applicable. This file helps with follow-up, but it does not replace the statutory obligation to preserve accounting documentation or establish a universal retention period: CFF, Article 30.
Frequently asked questions
Is a reference number enough to close the procedure?
For internal control purposes, no. Review the acknowledgement and distinguish receipt, payment and response. Close only the applicable stages supported by evidence.
Does consultation authorization allow tax returns to be filed?
The specific authorization cited permits consultation of an opinion, not submission or signing of any tax procedure: SAT, third-party authorization.
Who keeps the documentation?
Agree on who organizes and delivers the file without confusing that task with the taxpayer's obligations. Preservation of accounting documentation is regulated by Article 30 of the CFF.
