French Use Case n°12: Transparent intermediary handling invoices for its purchasing principal
A transparent intermediary, as defined by VAT, acts as an intermediary between two people in the negotiation of a contract and canvassing for suppliers or customers.
For VAT purposes, a transparent intermediary is deemed to be acting on behalf of and in the name of a third party.
He appears as the principal's representative in his dealings with third-party contractors (BOI-TVA-CHAMP- 10-10-40-40, § 20).
In practice, the principal can be either the supplier or the customer.
In principle, transparent intermediaries are required to submit at least two invoices:
An invoice issued by the intermediary for its intermediation services (PS)
Intermediation operations for this type of intermediary are considered to be supplies of services independent of the
intermediation service itself (BOI-TVA-CHAMP-10-10-40-40, §40). As a result, intermediary services are subject to their own
VAT regime and must be invoiced.
An invoice issued by the supplier/service provider in the customer's name.
In principle, the main invoice is made out by the supplier in the name of the recipient of the goods or services.
When the main invoice and the intermediary invoice are issued between two taxable persons established in France, they fall
within the scope of electronic invoicing and transit between the supplier's platform and that of the recipient:
The main invoice passes directly from sender to recipient via the chosen platforms,
Billing data will be transmitted via the biller's platform.
If the transparent intermediary is also acting as the principal's invoice manager, i.e. receiving invoices on behalf of the customer, so that the intermediary receives invoices directly on his behalf, the "ADRESSEE A" (INVOICEE) block may be used to indicate on the invoice a third party other than the purchasing customer. If the principal is on the PPF, he will have access to the invoice (except for EDI access).
In this case, if an invoice report or summary invoice is sent to the purchaser via an intermediary, these documents will be outside the scope of electronic invoicing and will have to be transmitted outside the tool.
Background
French Use Case n°12: Transparent intermediary handling invoices for its purchasing principal
A transparent intermediary, as defined by VAT, acts as an intermediary between two people in the negotiation of a contract and canvassing for suppliers or customers. For VAT purposes, a transparent intermediary is deemed to be acting on behalf of and in the name of a third party. He appears as the principal's representative in his dealings with third-party contractors (BOI-TVA-CHAMP- 10-10-40-40, § 20). In practice, the principal can be either the supplier or the customer. In principle, transparent intermediaries are required to submit at least two invoices:
An invoice issued by the intermediary for its intermediation services (PS)
Intermediation operations for this type of intermediary are considered to be supplies of services independent of the intermediation service itself (BOI-TVA-CHAMP-10-10-40-40, §40). As a result, intermediary services are subject to their own VAT regime and must be invoiced.
An invoice issued by the supplier/service provider in the customer's name.
In principle, the main invoice is made out by the supplier in the name of the recipient of the goods or services.
When the main invoice and the intermediary invoice are issued between two taxable persons established in France, they fall within the scope of electronic invoicing and transit between the supplier's platform and that of the recipient:
If the transparent intermediary is also acting as the principal's invoice manager, i.e. receiving invoices on behalf of the customer, so that the intermediary receives invoices directly on his behalf, the "ADRESSEE A" (INVOICEE) block may be used to indicate on the invoice a third party other than the purchasing customer. If the principal is on the PPF, he will have access to the invoice (except for EDI access).
In this case, if an invoice report or summary invoice is sent to the purchaser via an intermediary, these documents will be outside the scope of electronic invoicing and will have to be transmitted outside the tool.
NOTE: The text/pictures of this use case no. 12 were taken from the French government site! The text was extracted from V2.3 - deepl English DOCX and any pictures were taken from V2.2 - original English PDF)