Use case 25: Voucher and gift card management
Single-use (BUU) and multi-use (BUM) vouchers and cards have different VAT and e-invoicing treatments.
This use case is still under discussion and is therefore subject to significant changes.
Description
This use case covers vouchers and gift cards, which receive different.tax treatment depending on whether they can be used once or multiple times.
- Key characteristics
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- Bon a Usage Unique (BUU)
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A single-use voucher, for which the place of supply and the applicable VAT rate are known at the time of issuance. This means that both VAT and e-invoicing (B2B) or e-reporting (B2C) are due at each transfer or sale, so redemption is not a separate taxable event. Example: A theater card that grants a certain number of performances, whose place of taxation and VAT rate are known.
- Bon a Usages Multiples (BUM)
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A multi-use voucher, for which the place of supply and the applicable VAT rate are unknown at the time of issuance. This means that both VAT and e-invoicing (B2B) or e-reporting (B2C) are only due at redemption. Example: A gift card usable across a store network, whose place of taxation and VAT rate are unknown.
- Commissions and management fees
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These are taxable services throughout the voucher marketing chain and must be invoiced separately (B2B e-invoicing).
- B2B and B2C
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B2B voucher sales are within the e-invoicing scope. B2C voucher sales are within the e-reporting scope.
- Commission invoices
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Commission invoices between issuers, distributors, and providers follow standard B2B e-invoicing.
- Relationship to other use cases
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Use case 30 (VAT already collected) may apply if a BUM redemption in B2C is later followed by a B2B invoice request.
Business and tax context
- Legal and regulatory framework
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Voucher taxation follows Article 269 of the General Tax Code (CGI) and BOI-TVA-BASE-20-40. For a BUU, VAT is due at each transfer under the same conditions as the underlying operation:
- Delivery of goods
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VAT is payable upon delivery of the voucher.
- Provision of services
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VAT is payable upon payment of the voucher.
For a BUM, the sale is outside the VAT scope, so VAT is due at redemption under normal rules for the underlying operation.
- Common business scenarios
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- BUU
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Theater subscription card (specific venue, known VAT rate).
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Pre-paid fuel card for a specific gas station chain (known product, known VAT)
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- BUM
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Multi-brand gift card usable across various retailers (place of taxation and VAT rate undetermined).
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Department store gift card covering goods and services at different VAT rates
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- Tax and accounting implications
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- BUU
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Each sale or transfer generates a VAT event. If the BUU is sold B2B, standard e-invoicing applies. Redemption does not generate additional VAT. If the issuer differs from the provider, the provider invoices the issuer for the underlying service at redemption.
- BUM
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Each sale generates no VAT event and is outside both e-invoicing and e-reporting. At redemption, VAT is triggered. e-reporting (Flow 10.3 and 10.4) is required for B2C redemption and e-invoicing for B2B redemption. VAT chargeability follows the underlying operation rules.
Key data requirements
- BUU (sale)
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Field ID Description Value BT-3 Invoice type code 380 (if B2B sale) Standard BT-* All invoice fields Per normal invoice requirements Flow 10.3 E-reporting If B2C sale: daily cumulative sales - BUM (redemption)
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Field ID Description Value BT-3 Invoice type code 380 (if B2B redemption) Flow 10.3 E-reporting If B2C redemption: daily sales Flow 10.4 Collections If service with VAT on receipt
Implementation considerations
- Seller considerations
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- BUU
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Standard invoicing at each sale or transfer, track subsequent transfers in the chain.
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When the issuer is not the provider, the provider must invoice the issuer at redemption (B2B e-invoicing).
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- BUM
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No invoice at sale. Declare VAT at redemption in e-reporting (B2C) or e-invoicing (B2B).
- Buyer considerations
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- BUU
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Standard invoice processing with VAT deduction at purchase.
- BUM
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No invoice at purchase. VAT deduction only at redemption when B2B invoice received.
- General considerations
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Systems must distinguish BUU from BUM for correct VAT timing.
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The PA-E must support both e-invoicing and e-reporting flows depending on the voucher type and context.
Important:When the voucher issuer differs from the service provider, the provider requires visibility into voucher redemption events to trigger invoicing to the issuer. The Sovos solution handles this through its user interface with role-based permissions, so providers and issuers can coordinate redemption-triggered invoicing and commission management across the voucher lifecycle.
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- SCI mapping
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Standard SCI invoice mappings apply for BUU B2B sales and BUM B2B redemption invoices. No specific voucher-type SCI fields exist: The distinction is managed through business logic and VAT timing.
