e-invoicing

Compliance Network Implementation Guide

Use case 4: Partial third-party payment (subsidy, insurance)

When payment is split between the buyer and a third-party payer, the seller uses the payer block for the third party and tracks separate Encaissée statuses for each payment portion.

Description

This use case covers invoices where payment is split between the buyer and a third-party payer known at invoicing time. A typical scenario is an insurance claim where the insurer pays the repair cost minus the deductible (franchise), and the buyer pays the deductible plus potentially all the VAT.

The EN16931 standard and its UBL/CII syntaxes do not natively support multiple payers. However, the EXTENDED-CTC-FR profile lets you designate one third-party payer in the EXT-FR-FE-BG-02 block, while the buyer retains the ability to also send a payment. The BT-113 (Prepaid Amount) field is used to show the third-party portion, making the net payable (BT-115) equal to what the buyer must pay.

When payments from different payers are received on different dates, separate Encaissée lifecycle statuses must be sent, each with the correct VAT breakdown corresponding to the portion paid.

Key characteristics
Multiple payers
EN16931 does not support multiple payers — designate one primary payer (typically the larger amount) in EXT-FR-FE-BG-02.
Payment amount
BT-113 shows the third-party payment amount; BT-115 shows the buyer portion.
Split payment
Use BT-22 (Note with code PAI) to explain the payment split.
If VAT on receipt
Send separate Encaissée statuses for each payment with the correct VAT breakdown.
Insurance scenario
Insurer typically pays HT minus franchise; buyer pays franchise and all VAT.
Relationship to other use cases

Use case 4 extends use case 3 (Third-Party Payer) by introducing partial payment. While use case 3 assumes the third party covers the full amount, use case 4 handles the split. It differs from use case 2 (Already Paid) because payment has not yet been fully made. The VAT treatment complexities (particularly for insurance scenarios, where the insurer does not reimburse deductible VAT) make this use case more nuanced than use case 3.

Business and tax context

Legal and regulatory framework

The same legal framework as use case 3 applies: Article 289 bis CGI needs electronic invoicing through authorized platforms. The EXTENDED-CTC-FR

A key tax consideration arises in insurance scenarios: if the insurer were to reimburse VAT that is otherwise deductible by the buyer, this would result in a windfall gain. Insurance reimbursement therefore typically covers the HT amount minus the franchise, while the buyer pays the franchise plus all VAT.

Common business scenarios
Vehicle repair with insurance
Insurer pays repair cost minus deductible; buyer pays deductible and VAT.
Property damage claim
Insurance covers building repair; tenant or owner pays franchise.
Government subsidy
A subsidy covers part of an equipment purchase; enterprise pays the remainder.
Employee health expenses
Mutual insurance covers a portion; employer covers the rest.
Tax and accounting implications

The VAT breakdown in Encaissée statuses must accurately show the economic reality of each payment. In the insurance example: the insurer payment Encaissée has only the HT portion (no VAT), while the buyer payment Encaissée has the franchise amount plus the full VAT amount.

If both payments are received on the same day, a single Encaissée status for the full amount may be sent. If received on different dates, two separate Encaissée statuses are needed.

Important: When the insurer reimburses a deductible VAT amount, this would be a gain for the enterprise. The insurer therefore typically reimburses the HT amount minus the franchise, and the buyer pays the franchise plus all VAT.

Key data requirements

Field ID Description Value
BT-3 Invoice type code 380 (Standard invoice)
EXT-FR-FE-BG-02 Payer block Third-party payer (for example, insurer)
EXT-FR-FE-43 Payer name Name of third-party payer
BT-112 Total amount with VAT Full invoice amount including VAT
BT-113 Prepaid amount Third-party portion
BT-115 Amount due Buyer portion (franchise and VAT)
BT-21 Note subject code PAI (payment information)
BT-22 Note Explanation of payment split
BT-23 Billing framework B1/S1/M1 (standard)

Implementation considerations

Seller considerations
  • Calculate the payment split between buyer and third-party payer correctly.

  • Track payments from both sources and issue separate Encaissée statuses if received on different dates.

  • Each Encaissée must have the correct VAT breakdown for that specific payment.

  • Set up interaction with the third-party payer for payment tracking and recovery.

Buyer considerations
  • Understand the payment split and pay their portion (BT-115).

  • May need to set up interaction with the third-party payer (for example, insurer).

  • Keep documentation for VAT deduction purposes.

General considerations
  • PA-E must support the EXTENDED-CTC-FR profile for the payer block.

  • Systems must handle partial payment tracking and multiple Encaissée statuses.

Note: When the third-party payer (for example, insurer) needs visibility into the invoice, payment status, and Encaissée lifecycle events, the Sovos solution handles this through its interface with role-based permissions. The insurer or subsidizing entity can be granted tailored access for the relevant invoices and statuses without needing separate platform integration.
SCI mapping
Field SCI path
BG-4 Seller Invoice/AccountingSupplierParty/Party
BG-7 Buyer Invoice/AccountingCustomerParty/Party
BT-3 Invoice type Invoice/InvoiceTypeCode
EXT-FR-FE-BG-02 Payer Invoice/PaymentMeans/PaymentMandate/PayerParty
EXT-FR-FE-43 Payer name Invoice/PaymentMeans/PaymentMandate/PayerParty/PartyName/Name
BT-112 Total amount with VAT Invoice/LegalMonetaryTotal/TaxInclusiveAmount
BT-113 Prepaid amount Invoice/LegalMonetaryTotal/PrepaidAmount
BT-115 Amount due Invoice/LegalMonetaryTotal/PayableAmount
BT-22 Note Invoice/Note
BT-84 Payment account Invoice/PaymentMeans/PayeeFinancialAccount/ID