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VAT: can I send my invoices in PDF format?

Substituting paper invoices with an e-mail including the invoice as a PDF file

06/04/2020

In the present context, many of you have asked us about the possibility to replace paper invoices by an e-mail including the invoice as a PDF file.

Updated on 3 April 2020 to take into account the tolerance measure made public on 2 April 2020 by the French Tax Authorities

As a principle, the possibility of using an electronic invoice has been provided for by article 289, VI of the French Tax Code since 2013.

Three electronic invoicing methods co-exist:

  • the complete dematerialisation within the framework of the computerised exchange of data (EDI);
  • the sending of an electronic invoice secured by an advanced electronic signature;
  • the other electronic invoices not covered by the first two technologies and, in particular, the electronic document sent by e-mail.

These three methods imply the recipient's acceptance.

With regard to the sending of an electronic invoice by e-mail, its implementation is facilitated by administrative guidelines. Indeed, it stipulates that the acceptance may be express (formalised between the parties prior to sending), but also tacit and, in this situation, result for example from the processing of the invoice by the client or by the granting to the latter of a reasonable period during which he can request a paper invoice.

The issuance of invoices in PDF format sent by e-mail is therefore possible but it should be kept in mind that:

  • the invoice must, in principle, be issued and received in electronic format, which implies, in this case, that it is issued in PDF format (native document). The sending of a printed, then scanned document should therefore be avoided;
  • And, as for a paper invoice, the taxpayer must guarantee the authenticity, integrity and legibility of the electronic invoice from its issuance until the end of its conservation period by implementing controls which enable a reliable audit trail to be established between the invoice issued or received and the delivery of the goods or services on which it is based (reliable audit trail).

On a temporary basis and for the duration of the health crisis period (for now, until May 24th), the French tax authorities accept:

  • The issuing of paper invoices (in practice: their printing) before they are scanned and sent electronically, without having to send the corresponding paper invoice by post, including for the purposes of the recipient’s VAT deduction rights;
  • The storage of the scanned invoices by the recipient during the state of emergency period, and after its outcome, their printing or scanning under the conditions laid down by Article A.102 B-2 of the Tax Procedure Handbook for the purposes of their archiving. It should be noted that the issuer, for his part, must, in all cases, archive the invoices under the conditions of ordinary law (initial paper medium or scanning in according with the aforementioned article).

Do not hesitate to reach out to your usual contact persons in our specialised VAT teams who remain at your disposal for any question.


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