French subsidiaries of international groups: the time for electronic invoicing in france is approaching! Anticipate a revolution in your organization! Be ready
As a reminder, the obligation to use electronic invoicing comes from an EU provision.
In France, according to the order of 26 June 2014, public sector suppliers must already invoice electronically; The obligation of e-invoicing concerning other companies had been postponed till now.
Electronic invoicing: Major deadlines
The next major deadlines for the e-invoicing obligation in the non-public domain will be as follows:
1st of July 2024 :
• E-invoices reception: all VAT-registered businesses will have to be able to interpret electronic invoices when receiving them-
• Issuing electronic invoices: mandatory for all large companies
From the 1st of January 2025:
• Issuing electronic invoices: mandatory for all intermediate sized companies
From the 1st of January 2026:
• Issuing electronic invoices: mandatory for all medium sized companies and micro business
Before these final deadlines, companies wishing to invoice electronically before being obliged to do so must obtain the agreement of their customers.
From the 1st of July 2024, this customers acceptance is no more required.
Electronic invoicing: 3 diverse solutions
• Simple dematerialized invoice (pdf) and advanced e-signature as defined in a-2-art. 233 of the EU directive 2006/112/CE (a decree specifies the conditions for issuing and storing these invoices),
• In the form of a message structured according to a standard agreed between the parties under conditions specified by decree (Example EDI format),
• All kind of electronic invoicing method, provided that the firm meet the conditions of a good reliable audit trial !
Electronic invoicing: Comparison b to b French transactions and international
Electronic invoicing: Platform converting invoices in an electronic format (structured format)=PDP
Firms will be invited to upload their sales invoices issued on these platforms called PDP;
These platforms will:
• Check the conformity of the invoices (presence of all the compulsory mentions),
• Manage the centralized directory of the public tax platform (PPF)
• Convert your sales invoices (from pdf or Word, etc.) into a “structured” format only readable by the machines, but not by the humans.
• Check these invoices, if your software already produces invoices in structured format,
• Transmit your sales invoices subject to French VAT to your customers’ platforms and at the same time transmit them to the tax authorities, (double flow)
E-Invoicing: (mainly domestic invoices containing French VAT):
There will be no more direct sending to your customers
E-Reporting: (mainly B2C – Export-etc.):
• You will still need to send yourself these invoices to your customers,
• You will use your chosen PDPs for transformation of you B2C invoices or purchased invoices from EU firms into structured format (if not already done by your invoicing software) and deposit them on the tax administration platform.
Electronic invoicing: Our recommendations by stage for subsidiaries of foreign companies
Check the conformity of the invoices and the completeness of the compulsory mentions:
• Avoid any blocking of the sending of your invoices
• Avoid consecutive delays in your cash receipts
Identify PDPs present both on your territory and on the French territory:
Enable the harmonization and optimization of information transmission between countries
If no PDP with international presence can be found: identify a French PDP after cost comparison:
Will allow the French subsidiary to be a pathfinder at the group level, while waiting for the obligation of electronic invoicing in your country and the countries of your other subsidiaries
Choose the common structured format between the two countries if possible (e.g.: Invoice-X /Zugferd):
Promote interoperability between the different systems of your group
Check the completeness and the update of the SIREN numbers of all your customers in your invoicing software:
Anticipate the implementation of the centralized directory
Establishment of a timeline involving all teams:
Avoid the stress of potential last-minute bugs
Classify your different types of invoices and of customers:
• List the invoices that will go through the public portal (free) and those that will go through one or more PDPs (paid) for cost optimization.
• Survey your customers on their choice of structured format for future invoices that you will send them and their choice of PDP
Rethink your internal organization:
• Balance workload reductions and additional tasks,
• Quantify this balance in support of the PDP price offers,
• Set up a new distribution of tasks between your administrative teams,
• Adapt the internal control of the company.
Electronic invoicing: Endrix supports you
Switching to electronic invoicing: a real bet on the digitalization of your company! Not to be missed! Must be anticipated!
Endrix has created a support module with drawer missions to help you, do not hesitate to consult us for the progressive implementation of these steps.
Marie-Christine Mehenni, Endrix Partner, Chartered Accountant and Statutory Auditor