The transaction data return (e-reporting) for foreign enterprises without a permanent establishment in France

For the record, the electronic invoicing (e-invoicing) provided for in Article 289 bis of the French General Tax Code (CGI) covers all transactions of purchases and sales of goods and/or supplies of service carried out in France between persons subject to VAT established in France (see the section “I’m moving to electronic invoicing”).

Therefore, e-invoicing does not apply to foreign companies that do not have a permanent establishment in France.

However, there is an e-reporting obligation for foreign companies not established in France. E-reporting is the transmission of certain information (e.g. the amount of the transaction, the amount of VAT invoiced, etc.) relating to commercial transactions that do not fall within the scope of electronic invoicing to the tax authorities.

E-reporting has 2 components: transaction data and payment data.

What transactions are subject to data transmission (e-reporting) ?  

The transactions subject to e-reporting concern companies not established in France or their tax representative, if they have one, when the transaction they carry out is considered as located in France and subject to VAT; these are companies that trade with private individuals and, more broadly, non-taxable entities (business to consumer or BtoC), or with companies that are also not established in France.

N.B.: a foreign company not established in France is not liable for VAT in France if its customer is a French or foreign company established in France and identified for VAT in France; in that case, it is the buyer established in France who has the e-reporting obligation (reverse charge).

Accordingly, the taxable entity not established in France will also be liable for VAT on supplies of goods or services as referred to in Article 259a of the CGI when the buyer is a taxable entity not established in France or does not have a VAT ID number in France. However, a buyer which is not established in France (even if it is identified for VAT in France) who acquires goods located in France from a seller also not established in France is not subject to the e-reporting obligation (not reverse charge).

Lastly, transactions that are exempt from VAT pursuant to Articles 261 to 261 E of the CGI are not subject to e-reporting. This is the case, for example, with certain banking and insurance transactions, medical and health services, educational services and transactions carried out by non-profit organisations run on a non-lucrative basis.

Transaction data (Article 290 of the CGI):

International B2B:

This refers to transactions between two persons liable for VAT, one of which is established in France and the other in or outside the EU.

In the case of transactions between taxable entities, this includes taxable entities not established in France which carry out transactions from France with another taxable entity not established in France (exports, intra-Community supplies, sales or services in France).

NB: intra-Community acquisitions by a taxable entity not established in France are not to be included in its e-reporting.


  • Transactions carried out subject to a classification measure within the meaning of Article 413-9 of the French Criminal Code or covered by a confidentiality clause provided for on grounds of national security by a contract for works, supplies and services or the supply of equipment referred to in 1° to 4° of Article L.1113-1 of the French Public Procurement Code
  • Imports of goods


Transactions (sales and supplies of services) with a non-taxable entity (e.g. retail with individuals).


  • Transactions with a non-taxable entity if the operator that is not established in France is registered with a European one-stop-shop for VAT

Payment data (Article 290 A of the CGI):

This covers collection data as it is transmitted by the entity that receives the payment (issuer of the invoice), i.e. the collection date and the amount collected inclusive of VAT, broken down according to VAT rate, where applicable.

These transactions are referred to in Articles 289 bis and 290 of the CGI when they relate to supplies of services (if no option is available for the payment of VAT on debits and except for those for which the tax is payable by the buyer, in particular reverse charge ransactions).

How do I send my transaction data to the tax authorities ?

In general (except for certain special cases with international transactions), data on transactions submitted via e-reporting as listed by decree must be sent by the company carrying out the transaction using a government-registered private platform or via the public invoicing portal.

Multiple transmission modes and formats will be possible. If you have POS software, the data included in the daily data summary of a POS (ticket Z) may enable transmission of the data in question in a structured, paperless format. If you issue e-invoices to your individual customers, you will be able to file them directly in a structured, paperless format on the government-registered private platform of your choice or on the public invoicing portal. Either platform will extract the data for e-reporting as required by the tax authorities. In the latter case, however, the platform you use is not required to send the invoice to your customer. This will depend on the contract you have with said party.

In the absence of a POS, or invoice filing system or software, the company will have the option to enter or submit a summary report of transactions made over the period. Data transmitted by e-reporting will be limited to the amount of transactions and the corresponding VAT.

For more information, consult the FAQ (in French only) on the website which is updated regularly.

E-reporting application schedule 

For foreign companies not established in France, this schedule is the same as for companies established in France.

Reminder: foreign companies not established in France will not have an e-invoicing obligation and will therefore not be obliged to receive electronic invoices. Therefore:

  • as of 1 July 2024, this will affect large enterprises
  • as of 1 January 2025, it will also affect intermediate-sized enterprises (ISE)
  • as of 1 January 2026, it will affect all enterprises, including small and medium-sized enterprises (SME)

Notes on the different categories of enterprise:

  • a micro-enterprise is a company employing fewer than 10 people and with annual turnover or balance sheet total not exceeding €2 million
  • an SME (small and medium-sized enterprise) is a company employing fewer than 250 people and with annual turnover not exceeding €50 million or a balance sheet total not exceeding €43 million
  • an ISE (intermediate-sized enterprise) is a company outside the SME category, employing fewer than 5,000 people and with annual turnover not exceeding €1,500 million or a balance sheet total not exceeding €2,000 million
  • a large enterprise is a company that cannot be classified in any of the above categories

A company moves up to the next category:

  1. when the workforce criterion is exceeded
  2. if the workforce condition is not met, only if the annual turnover and balance sheet total are above the threshold

The concept of enterprise is that of legal unit, where a legal unit is identified by its Siren number.
The size of the enterprise will be assessed on 30 June 2023, based on the last financial year ended before that date or, in the absence of such a financial year, on that of the first financial year ended after that date.

DINR PRO 10/05/2023