Updated Dec 31, 2021
See impots.gouv.fr
Post from Laurent Poigt (PwC) on Linkedin (unofficial translation)
👉 After publishing a new version of the external specifications on 31/12/2021, a new version of the FAQ of 30/11/2021 has just been put online this week on impôts.gouv accompanied by a summary table of the operations carried out with the DOM/COM.
👉 These new guidelines are a departure from previous MFE presentations and would provide that:
– Deliveries of goods to or from the French overseas departments (excluding French Guiana / Mayotte) would be within the scope of the seller/supplier’s e-Reporting and not e-Invoicing as initially planned;
– The services provided for the benefit of a taxable person established in the French overseas departments (excluding French Guiana / Mayotte) or carried out by a taxable person established in those same departments would, on the other hand, fall within the scope of the seller/supplier’s e-Invoicing.
⚠️ This new scope of application will however deserve to be 🔺🔻 confirmed 🔻🔺, in particular with regard to the ordinance and the provisions provided for by the Official Bulletin of Public Finances (BOI) which provides in particular that exports of goods constitute supplies of goods within the meaning of a of 1 of I of Article 289 of the CGI. The ordinance specifying for its part that the “invoices relating to the transactions mentioned in a and d of 1 ° of I of Article 289” fall within the scope of the obligation of e-Invoicing since “the issuer of the invoice and its recipient are taxable persons who are established”.
⚠️ In addition to the articulation with the ordinance, the very logic of this difference between delivery of goods (possibility of continuing to issue/receive paper invoices, pdf, etc.) and provision of services (obligation to use a platform, PDP or PPF) will have to be confirmed.
🔸 In order to be ready for the date of 1 July 2024, the date of entry into force of the obligation to receive invoices in electronic format applicable to all taxable persons, it is essential to conduct a first phase of identification, through a 360 Diagnosis, of the axes of adaptation and evolution that will have to be deployed, while identifying the specific business cases and constraints related to your activity, your tools or more generally to your organization.
Source Laurent Poigt
