edmundgray
commented
1 year ago Single Taxable Person:
Under Article 256 C of the CGI, a group of legally independent entities that are closely bound to one another by financial, economic, and organizational links are treated as a single taxpayer for VAT purposes. This means that for eInvoicing, transactions between entities within the same group would be treated differently from transactions between separate entities.
This is a requirement of the VAT Directive also.
Heres an example;
three companies: Company A, Company B, and Company C. All three companies are part of the same VAT group and are treated as a single taxable person under Article 256 C of the French General Tax Code (CGI).
Now, if Company A sells goods to Company B, this transaction is considered an internal transaction within the VAT group. As such, it would not be subject to VAT under Article 256 C. Therefore, the eInvoice issued by Company A to Company B would not include any VAT calculation.
On the other hand, if Company A sells goods to Company C, which is not part of the VAT group, this transaction would be subject to VAT. Therefore, the eInvoice issued by Company A to Company C would include a VAT calculation.
Background
'Single taxable person within the meaning of Article 256 C of the CGI'
French Use Case n°29: Single taxpayer within the meaning of article 256 C of the CGI
This management case concerns transactions external to the single taxable person, i.e. transactions between a member
of a single taxable person and a third party to that single taxable person.
Transactions between members of a single taxable entity are outside the scope of e-invoicing and will not be managed by the PPF (see PDP service offering).
As part of the process of bringing France's VAT group into line with the VAT Directive 2006/112/EC (already implemented in 20 EU member states), a VAT identifier and a SIREN will be created for the single taxable entity, which will become solely liable for VAT on behalf of all its members. These two identifiers will have to be indicated, in addition to their own identifiers, on all invoices issued by members of the single taxable entity on its behalf.
The conditions for adding this data to the standard are currently being studied.
In the case of a single taxpayer :
Data relating to the member of the single taxable person must appear in the VENDOR block (BG-4). Field BT-29a should be used to enter the SIREN of the single taxable person. The statement "Member of a single taxable person", mandatory for all invoices issued to a single taxable person, must be entered in the invoice note in BT-21 (see G1.52), with a note subject code of "TXD".
In the absence of a block dedicated to the single taxable person in standard EN16931, data relating to the single taxable person, other than the SIREN, must appear in the VENDOR'S TAX REPRESENTATIVE block (BG-11).
The business rules dedicated to the single taxable person are G1.76, G1.78, G1.79 and G1.52 (see Appendix 7).
NOTE: The above text was taken from case no. 29 of the PDFs - originally from the French government site: https://www.impots.gouv.fr/specifications-externes-b2b (see uses cases V2.2 & our translated use cases V2.3)