Sending scanned paper invoices by e-mail during the health emergency period: can the obligations of the parties be simplified by tolerance?

Further to a question of the French organization MEDEF (representing French businesses) about the consequences of sending scanned paper invoices by e-mail during the health emergency period, the French tax authorities specified its position on its website impots.gouv.

The starting question

The question raised by MEDEF to the tax authorities is an extremely practical one.

The question is whether it is possible, in the event of sending a scanned paper invoice by e-mail during this period, to dispense the businesses to send the original invoice by post later on.

This exemption would indeed ease the obligations of businesses during this difficult period.

The Administration’s reply

In its reply, the administration first reminds the basic principles applicable to electronic invoicing.

To be qualified as an electronic invoice, the entire invoicing process must be electronic. Therefore, an invoice that was originally designed on paper and then scanned, sent and received by e-mail is not an electronic invoice but a paper invoice.

However, during this health emergency period, it will be possible, including from a recovery right perspective, to send this type of invoice, issued in paper form and then scanned, by e-mail without the need to send the corresponding original paper invoice by post.

Nevertheless, in order to guarantee the authenticity of the origin, the integrity of the content and the legibility of these paper invoices, whether or not they are scanned for storage, the controls establishing a reliable audit trail must be put in place by the taxable persons who issue and/or receive them.

With regard to the rules for archiving at the customer’s level, the tax authorities mention that, by tolerance, it will be allowed, during this period, for the customer to be able to keep the “paper” invoice received by e-mail in PDF format. At the end of this period, it will be up to the client to keep it on paper by printing it or to scan it in accordance with the provisions of Article A.102 B-2 of the tax procedural code.

These simplification measures are therefore welcome.

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Vanessa Irigoyen

With more than 16 years of experience, Vanessa has extensive expertise in the implementation of international efficiency business models for customs, export control and indirect tax purposes. Her functions notably […]

Odile Courjon

Odile Courjon, Partner, has developed a strong expertise in indirect tax issues (VAT, wage taxes, excise taxes, export control and customs) in France and overseas. She advises her clients in […]