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France: Digital versions of invoices allowed, tax recordkeeping purposes

France: Digital versions of invoices allowed

Taxpayers are now allowed to prove expense receipts using a computerized version of the receipts for purposes of determining the tax base for tax and social security contributions, as of 1 July 2019.


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Since 30 March 2017, all paper invoices issued or received could be destroyed after scanning (under strict conditions) according to a provision of the tax law. However, the rules for retaining receipts of expenses required that taxpayers retain a hardcopy of the receipt for certain purposes. A failure to retain these hardcopies could be subject to tax and social liability reassessments. In particular, during a social security audit, inspectors could request a hardcopy of the expense receipts.

Computerized format

With a May 2019 decree, the rules for supporting documents required to establish the base of the social security contributions may be kept in computerized format effective 1 July 2019.

The digitalization format rules are described in Article A.102 B-2 of the tax procedures law (LPF), and clarify that the following principles must be applied:

  • An identical reproduction (especially colors)
  • Documentation of archiving operations and implementation of controls
  • Conservation of documents in PDF or PDF A/3 format
  • A time-stamp of the documents, using an internal time stamping source
  • Securing files by means of: (1) a server stamp based on a certificate compliant with at least the one-star general security reference framework (GRS); (2) a digital fingerprint; (3) an electronic signature based on a certificate that complies, at least, with the one-star general security reference framework (GRS); or (4) any equivalent secure device based on a certificate issued by a certification authority on the French trusted list (trust-service status list-TSL).

The rules under the decree allow companies to set up solutions for digitizing expense reports, without having to keep paper documents.

KPMG observation

Particular attention must be paid to the quality of digitization because the conditions (described above) are very strict and not all currently available solutions meet these criteria. Thus, a company that asks its employees simply to take a picture or image of their expense receipts would not meet the conditions of Article A 102 B-2 of the LPF and would have to continue to keep paper documents.

Companies may want to consider conducting a diagnostic evaluation of their current practice as well as how to implement the new rules.


For more information, contact a tax professional with KPMG Avocats in France:

Laurent Chetcuti | + 33 1 55 68 48 87 |

Armelle Courtois-Finaz | + 33 1 55 68 49 43 |

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