Overdue Annex 24 Balances: Real IMMEX Reconstruction Case
When an IMMEX company has been operating for years with inconsistent discharge criteria or incomplete per-entry traceability, its overdue Annex 24 balances can accumulate. Over time, that accumulation represents a tax liability that no longer reflects operational reality.
Most companies don’t realize this until it’s too late. As a result, when the time comes to regularize overdue temporary imports, they calculate their exposure based on a historical record that was never audited.
Furthermore, under the 2024 reforms to Annex 24 Section C, the SAT can now use overdue inventory balances as grounds to deny renewal of the VAT and IEPS certification. Consequently, the risk is no longer purely fiscal: it can compromise the entire IMMEX program.
This article describes a real reconstruction case carried out by TradeWorks for an industrial company in northern Mexico.
The starting point: untracked accumulated balances
The company came to TradeWorks with a historical universe of temporary imports spanning approximately five years. At the time of the analysis, the previous control process had generated balances totaling over 50 million units in accumulated quantity and over USD $31 million in historical balance value.
Before any regularization decision was made, therefore, TradeWorks performed a full reconstruction of the same period. Each entry was reviewed individually, covering tariff code, unit of measure, value, and discharge record.
Reconstruction results
Once the period was reconstructed using traceable methodology, the universe changed substantially:
- Balance in quantity: from ~50,000,000 units to ~46,000 units (−99.9%)
- Balance in USD value: from ~USD $31.4 M to ~USD $1.1 M (−96.6%)
This difference does not represent missing goods. Instead, it reflects balances accumulated through inconsistencies in control criteria and documentary traceability — which were not real pending obligations.
The fiscal risk that was avoided
This is the most relevant finding of the case.
Had the company initiated regularization using the unaudited historical universe, the potential VAT, inflation adjustment, and surcharge exposure would have reached over MXN $200 million.
However, after reconstruction, the actual universe identified as requiring attention represented an inflation-adjusted VAT with surcharges of approximately MXN $7.8 million — a reduction of 96% of the estimated fiscal risk.
Additionally, by applying TradeWorks’ technical strategy — including scrap value treatment for the applicable entries — the final amount payable was reduced to approximately MXN $177,000.
These figures do not represent automatic savings. Rather, they reflect the result of correctly identifying what was a real obligation and what was accumulated historical noise, and of applying a documented, technically sound regularization strategy.
Ongoing control: clean operations from the cutoff date forward
Once TradeWorks took over the process, inventory control continued under a traceable and consistent discharge methodology. In the two years that followed, the company processed over 12.5 million kilograms and over USD $40 million in discharged value, with no accumulation of new discrepancies.
As a result, as of the most recent reporting date, 98.8% of entries carry a zero balance.
What does this mean for your company?
If your IMMEX company operates an Annex 24 system that has not been audited in the last two to three years, it is worth asking the question before the authorities ask it for you. Similarly, the same risk applies if there was ever a change of logistics operator, customs broker, or control system without a documented transition.
Do your overdue Annex 24 balances reflect real obligations, or years of accumulated discrepancies?
The answer can have a multi-million peso impact. Moreover, with the SAT actively monitoring overdue inventory balances, the time to find out is now.
TradeWorks provides Annex 24 audit and administration services for IMMEX program companies, and develops WES Control, the specialized Annex 24 inventory control software. Contact us to review the current state of your Annex 24.