Guatemala’s SAT Establishes New Guidelines for DTEs Issued by Courier Companies

CobroXCuentaAjena Complement for Courier Companies

DTEs for courier companies in Guatemala must comply with guidelines regarding the treatment of import VAT and Import Duties (DAI) collected on behalf of third parties.

The Superintendency of Tax Administration (SAT) has established criteria for operations carried out under the express delivery or courier modality, with implications for VAT, income tax (ISR), and electronic invoicing. Institutional Tax Criterion No. 1-2026 specifically addresses the tax treatment of these operations.

For companies in this sector, understanding these criteria is essential to reviewing their electronic invoicing processes and ensuring that amounts collected on behalf of third parties are properly recorded.

What Should Courier Companies Consider When Issuing DTEs?

The main aspect courier companies should review is the distinction between their own income from services provided and amounts collected on behalf of third parties.

When an express delivery company pays import VAT or DAI related to its customers’ goods and subsequently recovers these amounts, such amounts do not represent income belonging to the company.

For this reason, they must be kept separate from the amounts corresponding to the courier service provided.

What Is the CobroXCuentaAjena Complement?

The CobroXCuentaAjena complement allows the issuer to identify, within the Electronic Tax Document (DTE), amounts collected on behalf of third parties.

For courier companies, this mechanism is particularly relevant for recording items such as:

  • Import VAT.
  • Import Duties (DAI).
  • Other amounts collected on behalf of consignees, when applicable.

The purpose is to distinguish these amounts from the income that actually belongs to the company for the services it provides.

According to the published criteria regarding courier operations, amounts charged to customers for import VAT and DAI must be reported through the corresponding complement and must not form part of the company’s own VAT taxable base.

Do Import VAT and DAI Form Part of the Taxable Base?

No.

Amounts collected by the courier company on behalf of the customer do not constitute the company’s own income. Therefore, they should not be included in the VAT taxable base applicable to the service provided by the company.

This separation makes it possible to distinguish between:

  • The service invoiced by the courier company.
  • Import taxes paid on behalf of the customer.
  • Amounts subsequently recovered from the consignee.

Proper identification of these concepts is important for both electronic invoicing and the company’s accounting records.

Can These Amounts Be Used as Input Tax Credits?

The SAT’s tax criterion establishes that a courier company should not claim as its own input tax credit the VAT paid on the importation of goods belonging to third parties when it acts as an auxiliary of the public customs function.

The fact that the company’s Tax Identification Number (NIT) appears on certain import-related documents does not mean that the goods belong to the company or that the tax paid corresponds to an operation carried out on its own behalf.

Therefore, companies should carefully review the accounting and tax treatment of these amounts.

Are DAI Deductible Expenses for the Courier Company?

According to the tax criterion, DAI paid on behalf of third parties does not constitute a deductible expense belonging to the courier company either.

These payments correspond to obligations related to the consignees’ goods and are subsequently recovered from customers.

For this reason, they must be differentiated from the company’s own operating expenses.

How Should Amounts Collected on Behalf of Third Parties Be Recorded?

The invoicing process must clearly distinguish the services provided by the company from the amounts it collects on behalf of its customers.

In general terms, the process should include:

  1. Issue the corresponding DTE for the services provided.
  2. Identify the import VAT and DAI paid on behalf of the customer.
  3. Record these amounts through the CobroXCuentaAjena complement, when applicable.
  4. Keep these amounts outside the company’s own VAT taxable base.
  5. Maintain consistency between invoicing, accounting records, and customs documentation.

This approach ensures that the information reported in the DTE accurately reflects the economic nature of each amount.

Can an Addendum Be Used to Record These Amounts?

An addendum should not be used as a substitute for the structure established for amounts collected on behalf of third parties.

The information must be recorded in the fields defined by the corresponding DTE structure rather than simply as free-form text.

This is particularly important when electronic information must go through validation processes, as an addendum does not provide the same structure as a specific complement.

What Should Courier Companies Review in Microsoft Dynamics 365 Business Central?

For companies using Microsoft Dynamics 365 Business Central, properly managing DTEs for courier companies is essential to reviewing the configuration of their electronic invoicing processes and ensuring that amounts collected on behalf of third parties are handled correctly.

Companies should verify that their solution allows them to:

  • Differentiate their own services from amounts collected on behalf of third parties.
  • Correctly identify import VAT.
  • Record DAI associated with the transactions.
  • Generate the information required for the corresponding complement.
  • Prevent amounts collected on behalf of third parties from being incorrectly included in the taxable base.
  • Maintain consistency between commercial, accounting, and tax information.

Proper configuration can help reduce errors when issuing electronic documents and facilitate compliance with tax obligations.

Why Is It Important to Review These Processes?

Courier operations involve different tax and customs concepts that must be properly differentiated.

Incorrect treatment of amounts collected on behalf of third parties can create discrepancies between accounting records, electronic documents, and information related to import transactions.

In addition, the SAT criterion reinforces the importance of analyzing the economic substance of the transaction, distinguishing amounts that actually belong to the company from those that are merely paid or collected on behalf of the customer.

When Should These Guidelines Be Considered?

The tax criterion communicated by the SAT applies to operations carried out under the express delivery or courier modality.

Therefore, companies in this sector should review their current processes and determine whether their electronic invoicing configuration accurately reflects the established criteria.

The review should cover both internal processes and the configuration of the system used to generate DTEs.

How Can Your Company Prepare for These Requirements?

Courier companies can begin by reviewing their invoicing and accounting processes.

It is recommended to validate:

  • How import taxes are currently recorded.
  • How DAI paid on behalf of third parties is accounted for.
  • How DTEs are generated.
  • How amounts collected on behalf of third parties are identified.
  • How this information integrates with Microsoft Dynamics 365 Business Central.
  • Whether the current configuration complies with the structures required by FEL.

A preventive review can help identify potential inconsistencies before they affect daily operations or the generation of electronic documents.

The SAT’s new criteria for courier operations place particular emphasis on correctly separating the company’s own income from amounts collected on behalf of third parties.

Import VAT and DAI related to customers’ goods must receive differentiated treatment and be properly recorded in electronic invoicing.

For companies using Microsoft Dynamics 365 Business Central, having a properly configured tax localization is essential for managing these processes efficiently.

DTEs for Courier Companies require a properly configured solution that allows companies to differentiate their own services from amounts collected on behalf of third parties while maintaining consistency across commercial, accounting, and tax processes.

DTEs for courier companies require a configuration that allows companies to differentiate their own services from amounts collected on behalf of third parties while maintaining consistency across commercial, accounting, and tax processes.

At LLB Solutions, we help companies adapt Microsoft Dynamics 365 Business Central to the tax requirements of Guatemala and other countries across Latin America.

Would you like to learn how our Guatemala Localization can help you manage your tax and electronic invoicing processes? Contact us and discover how we can help.

info@llbsolutions.com | Guatemala Localization