Description

Restaurant notes to taxable persons fall within the scope of e-invoicing, but an administrative tolerance exists for notes below 150 EUR HT. Notes below 25 EUR to non-commercial customers do not require issuance. The resolution depends on whether the client is identified as a taxable person at the time of the transaction.

Three scenarios arise:

Scenario A

Note below 150 EUR HT where the taxable buyer does not request an invoice: the seller declares using B2C e-reporting (Flux 10.3/10.4).

Scenario B

The buyer requests a B2B invoice: if the sale was already recorded in the POS system and included in B2C e-reporting, the invoice uses billing framework S7/B7 (see use case 30); if the sale can be excluded from POS before e-reporting, a standard invoice with S1/B1/M1 framework applies.

Scenario C

Notes above 150 EUR HT to a taxable person: a B2B invoice is required.

Key characteristics

• Notes below 150 EUR HT without invoice request: B2C e-reporting (Flux 10.3/10.4).

• Notes below 25 EUR to non-commercial clients: no issuance obligation.

• Buyer requests invoice and sale already in POS: BT-23=S7/B7 (use case 30).

• Buyer requests invoice and sale excluded from POS: BT-23=S1/B1/M1 (standard).

• Notes above 150 EUR HT to taxable person: B2B invoice required.

• Cross-references use case 30 for S7/B7 framework details.

Relationship to other use cases

Use case 28 is closely related to use case 30 (VAT Already Collected) for the scenario where B2C e-reporting precedes a B2B invoice. Use case 6 (Employee Expenses B2C) covers the case where an employee pays personally at a restaurant. Use case 27 (Toll Tickets) shares the anonymous B2C treatment pattern. The 150 EUR HT threshold is specific to restaurant notes.

Business and tax context

Legal and regulatory framework

The 150 EUR HT tolerance is an administrative doctrine specific to restaurant services. Above this threshold, a full B2B invoice is required when the client is a known taxable person. The S7/B7 billing framework signals to the tax administration that VAT has already been collected through e-reporting, preventing double counting.

Common business scenarios

• Business lunch below 150 EUR: No invoice requested; seller declares using B2C e-reporting.

• Business dinner above 150 EUR: B2B invoice required; buyer gives SIREN and e-address.

• Post-payment invoice request: Buyer requests invoice after POS processing; S7/B7 framework.

Tax and accounting implications

For the S7/B7 scenario: the original B2C e-reporting (Flux 10.3/10.4) remains valid. The B2B invoice with S7/B7 framework lets the buyer claim VAT deduction while signaling that the seller's collected VAT was already declared. The Flux 1 from this invoice serves only for the buyer's pre-fill, not the seller's.

Key data requirements

Scenario A (B2C e-reporting)

Field ID	Description	Value
Flux 10.3	Daily B2C sales	Cumulative daily restaurant sales
Flux 10.4	Collections	If VAT on receipt: collection data

Scenarios B and C (B2B invoice)

Field ID	Description	Value
BT-3	Invoice type code	380
BT-23	Billing framework	S7/B7 (if sale in the POS) or S1/B1/M1 (if excluded)
BG-7	Buyer	Taxable person requesting invoice

Implementation considerations

Seller considerations

• Determine at point of sale whether a B2B invoice is needed (client request and amount threshold).

• If sale already in POS: use BT-23=S7/B7 and keep e-reporting as-is.

• If sale can be excluded from POS: use standard BT-23=S1/B1/M1.

• Notes above 150 EUR HT to taxable person: B2B invoice required.

Buyer considerations

• Request a B2B invoice if VAT deduction is needed, giving SIREN and e-address.

General considerations

• POS systems should support excluding sales from B2C e-reporting when a B2B invoice is created.

• The issuer's Plateforme Agréée (PA-E) must support both e-reporting and e-invoicing flows for restaurant services.

SCI mapping

Standard SCI mappings apply for B2B restaurant invoices. The key differentiator is the billing framework code in BT-23 (InvoicePeriod/DescriptionCode).

Field	SCI path
BT-3 Invoice type	Invoice/InvoiceTypeCode
BT-23 Billing framework	Invoice/InvoicePeriod/DescriptionCode
BG-7 Buyer	Invoice/AccountingCustomerParty/Party