Invoices, books and working papers alone do not prove a transaction happened
Presumption of non-existent transactions. Digital tax invoices (CFDI), accounting records and working papers do not, by themselves, constitute full proof of substance.
Official heading (Spanish): PRESUNCIÓN DE INEXISTENCIA DE OPERACIONES. LOS COMPROBANTES FISCALES DIGITALES POR INTERNET (CFDI), REGISTROS CONTABLES Y PAPELES DE TRABAJO NO CONSTITUYEN POR SÍ MISMOS PRUEBA PLENA PARA ACREDITAR SU MATERIALIDAD.
The ruling
The company defended the substance of its transactions with CFDI, accounting records and working papers. The Collegiate Circuit Court confirmed that, against the article 69-B presumption, their mere existence does not prove the transactions occurred: they record what was declared, not operating capacity or the infrastructure, machinery or production processes.
Our take
This is the series' most direct precedent and the one most companies should read. The reasoning would be circular otherwise: if the presumption assumes invoices can be issued without a real transaction, the invoice cannot prove the transaction. The same goes for books that merely mirror the CFDI. Substance is proven by what surrounds the transaction: deliveries, logs, emails, photos, evidence of staff and equipment. In our experience, companies that keep such evidence from the outset defend far better than those that rebuild it later.
What to do
- Keep contemporaneous operating evidence for each transaction: deliveries, logs, emails and photos.
- Require suppliers to show their infrastructure, staff and processes when engaged.
- Do not build a substance defense solely on CFDI, ledger entries and working papers.
Details
- Court
- Collegiate Circuit Court
- Type
- Isolated precedent
- Identifier
- (II Región)1o.6 A (12a.)
- Digital registry
- 2032637
- Published
- September 18, 2026
- Area
- Tax
- View official source ↗
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Prepared by Artegia for information only; not legal advice. Headings in English are unofficial translations. The official text is the one published in the Semanario Judicial de la Federación or the TFJA journal.