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France VAT B2B e-invoicing and B2C e-reporting July 2024 – v2.1 update

New technical guidance (version 2.1) for July 2024 1st wave of mandatory electronic invoicing (B2B) and electronic reporting (B2C)

France’s General Directorate of Public Finance has published further technical guidance for the July 2024 launch of its mandatory B2B e-invoicing regime for resident business. The latest specifications (v2.1) offers more details on use or ‘management’ cases, and well as additions. This includes new guidance on gift and purchase vouchers – single and multiple use vouchers. Plus the scope of debit notes for e-invoicing.

Registrations start Sep 2023 for July 2024 launch of B2B e-invoicing – following Mexican decentralised Continuous Transactions Controls model

The French tax authorities (Direction Générale des Finances Publiques) have clarified the July 2024 launch plans for B2B e-invoicing and B2C invoice reporting:

  • Sept 2023: The registrations process will start September 2023 with the launch of the Chorus Pro-based  portal, portail public de facturation (‘PPF’) – for companies  registering directly and potential certified agents (PDP).
  • Jan 2024: A pilot will be launched for a six-month period for businesses and PDP’s on a voluntary basis
  • Feb 2024: The first list of confirmed PDP agents will be published at the start of 2024.
  • Jul 2024: launch:
    • 1 Jul 2024 for large companies (more 5,000 employees; and either of following: €1.5 billion turnover; or €2 billion balance sheet)
    • 1 Jan 2025 for medium sized companies
    • 1 Jan 2026 for small businesses (less than 250 employees; and not exceeding either of following: €50 million turnover; or €43 million balance sheet)

France has opted for a Decentralised clearance model of Continuous Transaction Controls model (used in Mexico and Chile). This comes with the option to use certified agents (PDP, Plateformes de dématérialisation partenaires) able to clear invoices instead of direct reporting by the business via PPF. This is rather than the Italian-style Centralised clearance (see below for more details). See our global e-invoicing tracker.

Learn more about French VAT in our country guide.

European Commission grants e-invoicing VAT Directive derogation for France to launch in July 2024

On 21 January 2022, the European Commission granted France a temporary departure from Articles 218 and 232 of the VAT Directive to be able to impose mandatory electronic invoicing on certain B2B transactions. This clears the way for France to introduce electronic invoicing from July 2024.

18-months’ postponement of live Continuous Transaction Control (CTC)

France is introduce real-time VAT B2B electronic invoices and B2C e-reporting in a 3-year phased rollout starting with larger taxpayers from 1 July 2024 to January 2026. This is an 18-month delay on the original plan to launch 1 January 2023 based on the B2G Chorus Pro platform.

This will cover B2B, with separate e-reporting for B2C and cross-border sales. The new system will be based on the existing Chorus Pro platform, used for B2G e-invoicing.

There are no plans to change the French VAT return or SAF-T FEC regimes. Register for our FREE global VAT and GST news updates.

Small enterprises options to use e-invoicing prior to 2026

Small enterprises will be mandated to join the B2B electronic invoicing program from 2026. However, they will be encouraged to join the regime on a voluntary basis from the July 2024 launch date.  The same is the case for the new e-reporting requirement, although it wouldn’t be necessary to join e-reporting at the same time – they may join just the e-invoicing.

The tax authorities also confirmed that if the small enterprise does voluntarily register before 2026, they do not have to issue all invoices through the e-invoicing system. They may continue to issue paper invoices in some cases.

Lastly, it is confirmed that irrespective of whether the small company is mandates yet, its customers are still obliged to accept e-invoices from 1 July 2024.

Derogation from EU VAT Directive on e-invoicing

France now has it’s derogation from the European Commission and EU Council from the requirements from Articles 218 and 232 of the EU VAT Directive. This prevents member states from imposing e-invoices (and withdrawing paper-based invoices).

This is a temporary derogation between 1 January 2024 and 31 December 2016. After this time, France would need to apply for an extension based on evidence of the cost effectiveness in combating VAT fraud of the measure.  The Directive requires sellers of goods or services to provide paper-based invoices unless both the customer and seller agree to use electronic invoices.

Italy SdI rollout of its e-invoice regime required this application. Italy – and France likely to replicate – did not include non-resident businesses with a local VAT registration. However, the Direction Générale des Finances Publiques (DGFIP) has said it is looking at including foreign taxpayers.

You can check the right VAT calculations on e-invoices with our Advisor and Auditor services. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented. The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised Digital Reporting Requirements (DDR) across the member states. This originated from the 2020 Tax Action Plan measures for a fairer and more efficient EU tax regime.

Mexican certified e-invoicing agent model

The Mexican e-invoice system of having certified third parties acting as the e-invoicing intermediary has been adopted. So all taxpayers will need an outsourced Plateforme de Dématérialisation Partenaire (PSP) e-invoicing agent.  It is their role to create, validate and send the e-invoices to Chorus Pro. This includes the use of digital signatures on invoices.

This differs from the Italian SdI model which requires invoice submission and approval directly to the tax office prior to it forwarding to the customer.

CTC e-invoicing and real-time models

Invoice reporting model Examples Features
1. Real time invoice reporting Spain, Hungary, South Korea Invoice listing submitted immediately after invoice issued
No acceptance or regulation of invoice by tax authorities
2. Central platform exchange Italy, Turkey Platform responsible for invoice forwarding to customer
Customer or receiver may review and reject invoice
3. Central clearance Govt platform accepts invoices, validates, and buyer acknowledges invoice
Brazil, Colombia Pre-clearance variation - clearance before invoice exchange
Chile, Costa Rica Post-clearance - clearance short time after exchange
Document types not regulated and therefore inconsistent and may resort to email and similar
4. Decentralised clearance Mexico, Guatemala, Peru, France Certified e-invoice agent (PAC) submitts inoices
Document types not regulated and therefore inconsistent and may resort to email and similar

Scope of French e-invoicing

The following transactions will be included in the new regime:

  • Business-to-businesses transactions
  • Business-to-consumer transactions
  • Exports and imports transactions
  • Payment status of VAT invoices
  • Imports of services
  • Exports excluded

Information on B2C and intra-community, export and imports will have to be provided by other means to be determined.

How to create French e-invoice

French invoices may by created in the following formats:

  • Structured format: UBL invoice / CII D16B / XCBL
  • Hybrid format: Minimum UBL invoice / CPP hybrid / FACTUR-X (PDF-A3) / Minimum CII

There will be three options to create a French e-invoice:

  • Direct to PPF via:
    • Enabled accounting or ERP EDI route
    • In-house or external software with controls over digital signature
  • Use of outsourced approved providers, PPF, to file to PPF on your behalf

Europe e-invoicing and live reporting

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