In the last years, we have witnessed a continuously enhancing rhythm of the implementation of e-invoicing and/or e-reporting mechanisms on the Global landscape. France, one of the founding countries of the EU, as well as one of the most powerful European economies, started a few years back with the gradual introduction of the e-invoicing apparatus within its boundaries.
France’s E-Invoicing system was first introduced in commercial operations between private companies and public institutions.
A few years later, French institutions, in collaboration with the EU institutions and private sector representatives, started the grandiose and highly complex project called E-Invoicing and E-reporting for business-to-business transactions.
The mandatory usage of e-reporting and/or e-invoicing for private companies mainly established in France should start gradually, depending on the type of the company.
Important to emphasize here is that the mandate of e-invoicing and/or e-reporting is primarily centered around companies established in France. Still, this mandate doesn’t a priori mean that non-resident companies are out of scope. In some specific situations, the mandate covers their operations as well.
Timeline
The initial timeline for mandatory implementation of e-invoicing and e-reporting procedures, as defined by regulation, was the following one:
- From July 1, 2024, all companies established in France will be obligated to receive e-invoices.
- From July 1, 2024, large companies will be obligated to send e-invoices.
- From January 1, 2025, medium-sized companies will be obligated to send e-invoices.
- From January 1, 2026, small companies and micro-enterprises will be obliged to send e-invoices.
Due to the impossibility of implementing the project based on the initial regulatory timeline, the French Ministry of Finance has decided to postpone the mandate for, at the moment, an undisclosed time period.
It is only known that the new implementation timeline will be addressed during the preparation of the State Budget Law at the end of 2023.
Impact
One of the relevant points to consider is that e-invoicing and e-reporting are, in general, two separate requirements for companies.
Electronic Invoicing represents an obligation that will impact companies established in France and designate a digitalization of the invoicing requirements, mirrored through the modality of creation, transmission, reception, and storage of the invoices.
On the other hand, digital reporting depicts a method by which the transactional data of a single operation will be generated, transmitted, and stored by the companies that operate under the French General Tax Code. It means that the digital reporting mandate could impact non-resident companies as well, mainly in regard to B2C transactions.
Aleksandar Delic
1stopVAT Indirect Tax Researcher (Global Content)