The new upcoming French e-invoicing regulations will also affect the B2B meetings and events industry and how payments are processed for events. The French Tax Authority is introducing new controls on how to get real-time invoice data while aiming to digitalize the French economy.
Like what Italy, Serbia, Poland, India, Turkey, Saudi Arabia, and most of the Latin American countries have begun to do, electronic invoices will become mandatory for domestic transactions, which encompasses Hotels and Agents alike. On top of that, France went one step further and they will also introduce e-reporting requirements for those international invoices that are outside of the e-invoicing scope. Those invoices issued for international counterparts may still be in PDF format, however, data from those invoices will have to be transmitted through the public invoicing portal almost in real-time. In short:
- E-invoicing: Mandatory for domestic (within France) transactions
- E-reporting: Mandatory for cross-border (international) transactions.
Not every business will be affected at the same time. Large Hotel chains will likely be affected first. France is introducing a phased approach rollout based on company size. Therefore, the timeline is as follows.
For Accounts Payable
- July 2024: No matter the size of the company, every taxpayer will have to be able to receive and process an e-invoice.
- July 2024: Large enterprises will have to issue e-invoices to all their customers.
- January 2025: Medium-size (ETI) businesses will have to issue e-invoices to all their customers.
- January 2026: The remaining entities (PME) will have to start issuing e-invoices to all their customers.
The e-reporting obligation of international invoices comes into effect at the same time as e-invoicing.
|Employee number||Annual turnover||Balance sheet|
|Large Enterprises||≥ 5000||≥ 1.5 B eur||≥ 2 B eur|
|Medium Size (ETI)||< 5000||< 1.5 B eur||< 2 B eur|
|Small & Micro (PME)||< 250||< 50 M eur||< 43 M eur|
As long as one of the three criteria is met, the taxpayer will be categorized in that section.
E-invoice format and exchange mechanisms
Invoices must comply with specific technical and legal requirements to be compliant. Only three formats will be allowed to issue an e-invoice in France. This means that for a company’s B2B meeting commission request, the company must be able to generate one of the following e-invoice formats:
- UBL 2.1: Universal Business Language. This is an XML-based structured invoice.
- UN/CEFACT CII: Cross-Industry invoice. This is an XML-based structured invoice.
- Factur-X: This is a hybrid e-invoice. An XML embedded into a PDF.
At the same time, there will be two different mechanisms to exchange e-invoices:
- Via Registered private platform (also known as PDP): These are privately established actors that fulfill all e-invoicing and e-reporting requirements established by Public Finances Directorate General (DGFIP). They own a registration number from the Tax Authority, which they must renew every 3 years. PDPs mainly target mid-size and large companies aiming to automate their invoicing processes.
- Public invoicing portal (also known as PPF): The national e-invoicing infrastructure or HUB. It will receive e-invoices from suppliers and will deliver them to its respective counterparties.
French taxpayers will have to decide which of these two actors they leverage in order to generate and issue e-invoices.
New Message status obligations
Besides e-invoicing and e-reporting requirements, the “payment received” status message will also be mandatory from the supplier side. Once a business collects its M&E commissions, the business must issue a “payment received” status. These are only for transactions related to services, and event management companies fall under the service category. The payment amount collected, as well as the date and the related invoice number, must be included in the message.
This information is becoming more and more relevant to know for the tax authorities. Knowing the invoice paid status is a great mechanism to reduce tax fraud in the country. In the end, the most effective way to detect fraud is knowing if the invoice has been cashed or not. The payment status is already life in Latin American countries such as Mexico or Colombia because they have a cash-basis accounting (VAT is due from the invoice payment and not from the issuance of the invoice). In Europe, invoice paid status has not been adopted yet, but we are starting to see a change in that trend. Hotels and B2B event industry in general will have to adopt this. France being the first European country, Spain has also the intention to implement it once e-invoicing becomes mandatory and we will probably see it in more countries in the next couple of years (Belgium and Germany most likely).
Apart from that, invoice rejection notification will also be a new requirement. Whenever the invoice recipient is not satisfied with the invoice (for commercial reasons), the rejection status will have to be sent to the national platform (PPF) and to the supplier . This is also a mechanism to monitor the economy and detect tax fraud good time ahead.
Will GroupPay be ready to issue e-invoices in France?
GroupPay by Onyx CenterSource has an internal invoicing solution to generate and distribute compliant B2B event commission invoices. GroupPay is committed to e-invoicing ready for July 2024 in France, in order to help our French clients. GroupPay’s industry-first platform will allow B2B hospitality businesses to stay compliant in France by generating tax invoices in UBL 2.1 structured format on your behalf. See how this event payment solution platform can help ensure you remain compliant with all EU invoicing regulations. Learn more at onyxcentersource.com/GroupPay.