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France: Electronic invoices mandatory for business-to-business transactions; proposed effective 2023

France: Mandatory electronic invoices

The French finance bill project (published 27 September 2019) reflects the French government’s intention to make electronic invoices in business-to-business (B2B) relationships mandatory, effective January 2023. Under this proposal, paper (hardcopy) invoices would no longer be acceptable as of 2023.

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This proposal would have implications for value added tax (VAT) purposes.


Background

In 2015, the French government attempted to require electronic invoicing of B2B transactions; however, this plan was not successful because of the 2006/112 EU Directive that provides a customer must grant its approval before being invoiced electronically.

In the meantime, the Italian government obtained an “exceptional derogation” from the requirement for customer assent prior to electronic invoicing, and has implemented a rule for mandatory electronic invoicing between companies. Read TaxNewsFlash

French government officials have expressed their belief that France would be able to obtain a similar derogation because the purpose is to address VAT fraud.


Proposal in France

The French government plans to implement a system whereby:

  • VAT returns would be pre-filled with the data gathered from the invoices exchanged between companies.
  • The tax authorities then would be in a position to compare automatically the purchases data with the sales data.


KPMG observation

The French government’s proposal is viewed as being ambitious, and it confirms that new VAT legislative projects are becoming more and more data driven—in that the tax authorities want to have access to “best practices” implemented by other EU Members States, including mandatory B2B electronic invoicing, automatic upload of the VAT data to the tax administrations, and data mining.

Companies need to consider how to prepare for the mandatory electronic invoicing rules including considering how they can improve their tax data quality and strengthen their VAT controls (notably in the framework of a reliable audit trail). Practically speaking, companies need to pay attention to the requirements of an e-invoicing solution and how to customize such a system to comply with the proposed changes in 2023.


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

Laurent Chetcuti | + 33 1 55 68 48 87 | laurentchetcuti@kpmgavocats.fr

Armelle Courtois-Finaz | + 33 1 55 68 49 43 | acourtois-finaz@kpmgavocats.fr

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