The cost of processing each invoice is estimated at between 15 and 200 euros (the width of the range is due to differences in invoicing systems and estimation methods). The breakdown of this cost is approximately one third for the supplier who issues the invoice, and the remaining 2 thirds for the customer who has to pay it. Hence the importance of optimizing this obligatory but non-productive item.
That said, the challenge of dematerializing invoices must not only be considered from an economic point of view, but also from a legal and organizational one.
Tax dematerialization
The invoice is both a commercial document, conveying to the customer the agreed cost of his purchase, and a tax document, used to record VAT amounts and as evidence in the event of an audit.
The rules laid down by the tax authorities regarding dematerialization are based on this last aspect. They are, as always, very precise, which justifies the notion of tax-compliant dematerialization.
2 invoice types, 2 tax statuses
In most cases, the invoice is still issued on paper. In a few other cases, it's issued in electronic format, and that makes all the difference.
The tax authorities only consider originals, so they cannot be translated or transferred to another medium.
We can then consider the 2 cases:
the invoice is issued on paper: the customer must keep a paper copy.
the invoice is issued on an electronic medium: the operation must comply with certain rules (see paragraph "Rules for electronic invoices").
Tax-compliant dematerialization is the dematerialization of invoices according to rules accepted by the tax authorities. If these rules cannot be followed, paper documents must be produced, exchanged and archived in parallel.
2 types of electronic invoice format
An invoice can be sent electronically in 2 types of formats:
structured (automatically interpretable by computer program): traditional EDI standard (EDIFACT, VDA, ANSI, etc.), XML, or any other structured format (IDOC, csv text file, etc.),
unstructured (not automatically interpretable) : PDF, JPEG...(an uneditable image). Word and Excel are questionable because they can be modified.
Formats are said to be unstructured when there is no structure or tag that can be used to isolate and identify a given piece of information (customer name, VAT code, etc.).
Tax regulations: articles 289 bis and 289 V
European Directive 2001/115/EC, in force in all EU countries since January 1, 2004, authorizes the substitution of electronic invoices for paper invoices as legal documents.
Articles 289 bis and 289 V of the French General Tax Code (CGI) set out the conditions for dematerializing invoices for tax purposes:
Invoices may, subject to acceptance by the recipient, be sent electronically, provided that the authenticity of their origin and the integrity of their content are guaranteed by means of an electronic signature. Invoices transmitted in this way take the place of the original invoice for the purposes of article 286 and the present article. The conditions for issuing these invoices, for their electronic signature and for their storage are set by decree.
When they are in the form of a message structured according to a standard agreed between the parties, which can be read by computer and processed automatically and unambiguously, invoices must be issued under the conditions specified in article 289 bis. loi de finance rectificative du 30 décembre 2002, article 289 V du CGI (see Other links).
So it is with tax dematerialization, or rather, so it begins, since these very general provisions only lay down theoretical principles.
Failure to comply with these rules can have serious consequences. The penalty is a fine of 15 euros per missing item and per invoice. Worse still, in the case of proven fraud, the non-deductibility of VAT is at stake.
The dematerialized invoice
It is possible to send invoices in dematerialized form for intra- and extra-Community trade (European directive transposed into French law), in two ways:
EDI: since 1990, following a structured form adopted by both parties (supplier and customer),
electronically signed: in any form (Word, Excel, PDF, TIFF, JPEG, etc.) but certified by a signature provided by a trusted third party.
Dematerialized invoices are accepted by the tax authorities if they comply with certain rules. These include:
include the legal clauses required on all invoices,
meet the accounting requirements of companies and the trade,
comply with document retention rules (see the Computerized Accounting Control file),
comply with VAT directives,
comply with specific dematerialization instructions.
Rules for electronic invoices
The regulations lay down the conditions that electronic invoices must meet, depending on their format:
EDI, XML: French regulations (in contradiction with the European directive) require :
double the EDI transaction by sending a paper original
or meet 3 strict criteria to eliminate the need for duplicate paper.
These 3 criteria are :
- the sender and customer must store the electronic original in an electronic safe (on an unalterable medium),
- A daily list of exchanged invoices must be drawn up. All invoices should have a trace on the list, including errors and anomalies.
- draw up a list of partners (list of companies and organizations with which you exchange invoices).
PDF: the file must be electronically signed
Tax-compliant paperless solutions
Between the supplier and the customer, several players may come into play:
invoicing service providers, who can be connected to the supplier's ERP system and are responsible for issuing invoices in quantity, routing them and even collecting them,
intermediation platforms, which can act as hubs for the concentration and distribution of digital documents
trusted third parties, responsible for providing authentication of electronic documents,
third-party archivers, whose electronic safes will be used for archiving purposes,
dematerialization service providers, who receive invoices on behalf of customers, digitize them and create a file which is used in internal supplier invoice management processes.
Governance and dematerialization
Legislation is imposing new constraints on companies in terms of the sincerity and reliability of financial reporting. These include Sarbanes Oxley, LSF, Basel II, IAS...
The processes involved in publishing the company's financial statements (and there are many of them!) must be under control. They must be mapped and documented, process-related risks identified and an action plan put in place.
However, more is probably required of an electronic document than a paper one. Generally speaking, it's enough to produce a paper original for it to be considered probative. On the other hand, for an electronic document to be taken into account, an arsenal of measures must be put in place (signature, authentication, time-stamping, tracking, etc.). In fact, the electronic document circuit provides answers to new governance requirements.
On paper, for example, there is no automatic trace of when an invoice is received. Electronic documents, on the other hand, are time-stamped and tracked at every stage. For an auditor (internal or external), it's possible to know everything about the life of the invoice.
Validation of invoice dematerialization process
Edifrance, in collaboration with the Direction Générale des Impôts (French tax authority) and a law firm, offers to support companies in a self-assessment process for their dematerialized invoice exchange solutions.
The process includes 1 day's training to complete the self-assessment guide, with the help of a technical expert and a lawyer. Interested parties fill in the guide at their company and return it. Edifrance evaluates and responds.
GS1, Gencod
GS1 France has published a guide to dematerialized invoicing for its members who would like information on the new legal provisions applicable to this subject.
This document has been produced thanks to the experience of some GS1 France members on the subject.
In addition, since July 15, 2005, GS1 France has been involved in a process to certify the conformity of dematerialization tools. These tools are:
@GP : @GP Demat V1.0
Agena 3000 Genedi : V2.4 dematerialization module
B-Process: billManager 4.3
Cegedim: Global Invoice Services V1
Deskom : Pasrel V3.4
Edicom : Ediwin 4
EDT: EIMA V2
Influe: Webdemat 2.0.13
Seres: E-Facture V1.0
Source : guideinformatique.com
