In France, the Finance Law for 2020 initially provided for the phasing in of mandatory e-invoicing between taxpayers. The requirement to provide e-invoices to businesses is combined with a requirement to transmit the e-invoice data to the French tax authority (Direction Générale des Finances publiques-DGFiP)as part of an e-reporting mechanism. The system is a tax clearance model where e-invoice data is exchanged with the tax authorities. It will be supported by certified private agents who will first collect the data from taxpayers and then share it with the tax authority. The Finance Law for 2021 subsequently clarified the introduction of mandatory e-invoicing.

The French government published an ordinance on September 15, 2021, delaying the phased-in implementation of e-invoicing from July 1, 2024, to January 1, 2026, depending on the size of the company. Accordingly, the new timeline is as follows:

  • July 1, 2024, for large companies;
  • January 1, 2025, for small and medium-sized enterprises (SMEs) with a workforce of fewer than 5,000 people and annual sales of less than EUR 1.5 billion ($1.7 billion) or a balance sheet total of less than EUR 2 billion ($2.3 billion); and
  • January 1, 2026, for SMEs and very small enterprises (VSEs) with fewer than 250 employees and annual sales of less than EUR 50 million ($ 57 million) or a balance sheet total of less than EUR 43 million ($49 million).
On January 25, 2022, the European Union authorized France to introduce mandatory e-invoicing for businesses.

An update to the external specifications for B2B e-invoicing was published by France on December 30, 2021, which included e-reporting formats, components on the use cases and the directory, and appendices. Following the publication of the first version of the external specifications, the tax authority received comments from the public and companies.

The French General Directorate of Public Finance (DGFIP) updated the e-invoicing FAQs on February 28, 2022, which clarify, among other things:

  1. The scope and definition of e-invoicing;
  2. The gradual deployment schedule for mandatory reporting obligations beginning July 1, 2024, through January 1, 2026;
  3. The transactions excluded from e-invoicing;
  4. The rules regarding filing procedures and e-invoicing reporting; and
  5. The scope of e-reporting under the intra-EU sales regime.

A new version of DGFiP's Frequently Asked Questions on e-invoicing was released on May 24, 2022. This document is intended to provide further guidance related to the e-invoicing and e-reporting mandates that will become effective in 2024, including how to submit the sales transaction reports to the tax authority and how businesses that are part of the same economic group will be required to comply with the e-invoicing and e-reporting mandate.

On June 30, 2022, the DGFiP released version 2.0 of the technical documentation supporting the electronic invoice in France. Its purpose is to introduce multiple updates related to the methods of remittance of the reports, the life cycle of the invoices, and information about new businesses.

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