Description

Débours (reimbursable expenses) invoices cover expenses paid by a third party (agent, intermediary) on behalf of the buyer, which are then invoiced for reimbursement. These expense lines are classified with VAT category O (Out of scope/Hors VAT) because they represent a pass-through of costs, not a taxable supply.

Under the French e-invoicing reform, the treatment of débours invoices depends on their composition: pure débours invoices (containing only category O lines) are outside the scope of mandatory e-invoicing. However, mixed invoices containing both VAT-liable lines and débours lines (category O) are within scope and must follow the standard e-invoicing flow. The EXTENDED-CTC-FR profile supports mixing category O with other VAT categories in a single invoice, while EN16931 does not (this limitation is being revised).

Key characteristics

• Pure débours invoices (category O only) are outside e-invoicing scope.

• Mixed invoices (VAT lines + débours lines O) are within scope and follow the standard flow.

• EXTENDED-CTC-FR lets you mix O with other VAT categories in a single invoice.

• EN16931 does not let you mix O with other categories (under revision).

• VATEX-EU-79-C with category E can alternatively be used for expense reimbursement lines.

• Flux 1 extraction includes débours lines and their VAT breakdown.

Relationship to other use cases

Use case 16 is linked to use case 15 (Third-Party Order/Payment) as the reimbursement mechanism for expenses incurred by agents. It represents the financial counterpart of the commercial activity in use case 15. Use case 5 (Employee Expenses) addresses a different type of advance payment. The pure débours invoice is unique in being explicitly outside the e-invoicing scope.

Business and tax content

Legal and regulatory framework

Débours are regulated under general VAT principles: pass-through costs reimbursed at exact amount without markup are not subject to VAT. Invoice lines use VAT category O (Out of scope). When mixed with taxable lines, the EXTENDED-CTC-FR profile must be used to support the O category alongside S, E, or other categories.

Common business scenarios

Legal fees

A lawyer reimburses court filing fees alongside legal service fees (taxable).

Notary expenses

A notary passes through registration taxes alongside their service fees.

Agent expenses

An agent reimburses travel or advertising costs alongside their commission.

Tax and accounting implications

Category O lines have no VAT implication. When mixed with taxable lines in a single invoice, the taxable portion follows normal VAT rules while the O portion is excluded from VAT calculation. The buyer cannot deduct VAT on débours lines (there is no VAT to deduct).

Note:

Pure débours invoices (only category O lines) are outside the e-invoicing obligation. They can still be exchanged using platforms voluntarily. Only mixed invoices (O + other categories) using ​ EXTENDED-CTC-FR are subject to mandatory e-invoicing.

Sovos reports all invoices to the tax authority, whether they are pure débours invoices or not.

Key data requirements

Implementation considerations

Seller considerations

• Use the EXTENDED-CTC-FR profile for mixed invoices containing both VAT and débours lines.

• Categorize débours lines with category O and the appropriate VATEX codes.

Buyer considerations

• Category O lines have no deductible VAT.

• Process mixed invoices with both VAT-liable and débours components.

General considerations

• PA-E and PA-R must support EXTENDED-CTC-FR with mixed VAT categories including O.

SCI mapping

Field	SCI path
BT-3 Invoice type	Invoice/InvoiceTypeCode
BT-151 Line VAT category	Invoice/InvoiceLine/Item/ClassifiedTaxCategory/ID
BT-118 Doc VAT category	Invoice/TaxTotal/TaxSubtotal/TaxCategory/ID
BT-120 Exemption reason	Invoice/TaxTotal/TaxSubtotal/TaxCategory/TaxExemptionReason
BT-121 Exemption code	Invoice/TaxTotal/TaxSubtotal/TaxCategory/TaxExemptionReasonCode