Description

This use case covers invoices payable to a third-party distributor or depositary who is known at invoicing time and manages the commercial relationship including ordering, receipt, and potentially invoicing on behalf of the seller. Structurally, it is treated the same as use case 8, using the payee block (BG-10) to identify the distributor as a payment beneficiary.

However, use case 9 differs from use case 8 in several important ways:

• It is not factoring, so there must be no subrogation clause in the invoice

• The invoice type code remains 380 (standard) rather than 393 (factored).

• The distributor may manage the full commercial cycle (order, receipt, billing) but the seller keeps the fiscal relationship with the tax administration.

Key characteristics

• Same BG-10 (Payee) structure as use case 8, but invoice type remains 380 (standard).

• No subrogation clause (this is not factoring).

• The distributor manages order, receipt, and invoicing on behalf of the seller.

• Invoice replication to the distributor is not necessarily needed (unlike factoring).

• A key requirement is the distributor must inform the seller when the buyer has paid.

Relationship to other use cases

Use case 9 shares the same technical structure as use case 8 but serves a fundamentally different commercial purpose. Use case 8 involves financial intermediation (factoring), while use case 9 involves commercial intermediation (distribution). The different roles may be specified in the invoice but do not affect Flow 1 tax data. Use case 12 (Transparent Intermediary) is related but acts on behalf of the buyer rather than the seller.

Business and tax context

Legal and regulatory framework

Standard B2B e-invoicing under Article 289 bis Code général des impôts (CGI) applies. No special invoice type codes are needed; BT-3 remains 380. The distributor is identified in BG-10 as payment beneficiary. Additional roles (ordering, receipt management) can be specified in the invoice but do not affect Flow 1 data.

Common business scenarios

Pharmaceutical distribution

The depositary handles storage, orders, and payment collection for manufacturers.

Wholesale distribution

The distributor manages the sales channel and collects payment from retailers.

Publishing

The distributor handles order fulfillment and billing for publishers.

Tax and accounting implications

The same Encaissee obligations as use case 8 apply. The seller keeps fiscal responsibility. The distributor must inform the seller when the buyer has paid for the Encaissee status creation. No factoring-specific tax implications apply.

Key data requirements

Implementation considerations

Seller considerations

• Use standard invoice type 380 (not 393); populate BG-10 with distributor details.

• Do not include subrogation clause (ACC note code).

• Track payment notifications from distributor for Encaissee obligations.

Buyer considerations

• Pay to the IBAN in BT-84 (distributor account).

General considerations

• Invoice replication to distributor is optional (unlike factoring).

• Payment notification channel from distributor to seller is a key requirement.

Note: The distributor or depositary needs access to invoice lifecycle statuses to manage the commercial relationship. The Sovos solution handles this through its interface with role-based permissions, letting distributors track invoice approvals, payment status, and collection events for the invoices where they are designated as beneficiary.

SCI mapping

Field	SCI path
BT-3 Invoice type	Invoice/InvoiceTypeCode
BG-10 Payee	Invoice/PayeeParty
BT-59 Payee name	Invoice/PayeeParty/PartyName/Name
BT-61 Payee legal ID	Invoice/PayeeParty/PartyLegalEntity/CompanyID
BT-84 Payment account	Invoice/PaymentMeans/PayeeFinancialAccount/ID
BT-85 Account name	Invoice/PaymentMeans/PayeeFinancialAccount/Name
BT-86 Payment BIC	Invoice/PaymentMeans/PayeeFinancialAccount/FinancialInstitutionBranch/ID