Description

Unlike domestic B2B transactions that use e-invoicing through Flow 1, international B2B transactions are reported through Flow 10.1 (invoice data) and Flow 10.2 (payment data for services with VAT on receipt). There is no obligation to issue electronic invoices for international B2B. The obligation is limited to e-reporting of the transaction data.

This use case is structured around five areas:

• Difference between the validation rules of international and domestic invoices

• Outbound international sales

• Inbound international acquisitions

• Payment e-reporting on international sales

• Two specific sub-cases for triangular transactions (43a) and intra-EU stock transfers (43b)

Key characteristics

B2B international transactions

You are not required to issue electronic invoices for B2B international transactions, only e-reporting through Flow 10.

Outbound sales

Flow 10.1 for invoice data and Flow 10.2 for payment data (services with VAT on receipt only).

Inbound acquisitions

Flow 10.1 for acquisition data (simplified, no line detail required).

BR-FR-11

No SIREN obligation for international buyers (BT-47).

BR-FR-21/22

The electronic address of an international party is free-form (not SIREN-prefixed).

BR-FR-20

Note with code BAR signals treatment type (B2BINT versus domestic).

Currency handling

All amounts in invoice currency except VAT (TT-52), which must be in EUR.

Payment e-reporting exception

Article 290 A excludes transactions where VAT is due by the recipient (reverse charge) from payment e-reporting.

Intra-EU B2B e-invoicing

The VAT in the Digital Age (ViDA) Directive makes e-invoicing required for intra-EU B2B transactions from July 2030.

Relationship to other use cases

Use case 43 is the international counterpart to the domestic e-invoicing flow. The invoice structure follows EN16931 with BR-IC-XX (intra-community), BR-G-XX (export), and BR-AE-XX (reverse charge) rules. Use case 43a (triangular transactions) involves the simplification measure under Directive 2006/112/CE article 141. Use case 43b (stock transfers) uses e-reporting for transactions that may not generate a formal invoice. Use case 44 (DROM/COM/TAAF) extends use case 43 principles to French overseas territories.

Business and tax context

E-reporting for B2B international is mandated by Article 290 of the Code Général des Impôts (CGI) for outbound sales and acquisitions. Article 290 A covers payment e-reporting, explicitly excluding transactions where VAT is due by the recipient (reverse charge). The e-reporting obligation covers both EU-established and non-EU-established entities with French VAT obligations. E-reporting periods follow the taxpayer's VAT regime: Ten days for the standard monthly regime, monthly for the other ones.

Common business scenarios

Intra-EU goods sales

Intra-community supply (category K, VATEX-EU-IC)

Intra-EU service sales

Reverse charge by recipient (category AE, VATEX-EU-AE)

Export sales (non-EU)

Export exemption (category G, VATEX-EU-G)

Intra-EU acquisitions

Goods (K/AE with reverse charge) and services (AE)

Non-EU service acquisitions

Reverse charge (AE, VATEX-EU-AE)

Tax and accounting implications

Each international invoice generates e-reporting data through Flow 10.1. The taxpayer is responsible for producing the Flow 10.1 data, typically from their accounting or ERP system. For inbound acquisitions, only header-level data is required (no line detail). This was simplified to account for the fact that international invoices are often unstructured. Payment e-reporting (Flow 10.2) is only required for outbound sales of services where VAT is on receipt and not reverse-charged by the recipient.

Important:

Article 290 A excludes from payment e-reporting all transactions where VAT is due by the recipient (reverse charge). This covers the vast majority of intra-EU B2B sales. Payment e-reporting (Flow 10.2) primarily affects non-EU service sales where the French seller is liable for VAT on receipt.

Key data requirements

Outbound B2B international sale (Flow 10.1)

Field ID	Description	Value
TT-19	Invoice number	Invoice number from the B2B international invoice
TT-21	Document type code	380 (or applicable type code)
TT-22	Invoice currency	Invoice currency (EUR for amounts, VAT is always in EUR)
TT-33/34	Seller ID or VAT	SIREN (0002) + French VAT number
TT-37/38	Buyer ID or VAT	International ID (0223 for EU, 0227 for non-EU) + foreign VAT
TT-52	Total VAT amount	In EUR (may be 0 for exempt or reverse-charged)
BT-21=BAR	Treatment note	B2BINT (signals international treatment to the PA)

Inbound B2B international acquisition (Flow 10.1)

Field ID	Description	Value
TT-33/34	Seller (international)	International seller ID + foreign VAT number
TT-37/38	Buyer (French entity)	SIREN (0002) + French VAT number
TT-52	Reverse-charged VAT amount	In EUR, calculated by the French buyer
TT-56	VAT category	K (intra-EU goods) or AE (reverse charge)
TT-57	VAT rate	French rate applied for reverse charge
TT-58/59	Exemption reason	VATEX-EU-IC or VATEX-EU-AE + text

Implementation considerations

Seller considerations

e-reporting

When you send an invoice to Sovos for e-reporting purposes, the header parameter must indicate the submission is for e-reporting (not e-invoicing).

Intra-EU goods

Use VAT category K with VATEX-EU-IC.

Export (non-EU)

Use VAT category G with VATEX-EU-G.

Services with reverse charge

Use category AE with VATEX-EU-AE.

Currency

Provide all amounts in invoice currency. The VAT amount (TT-52) must be in EUR.

Transfer of ownership abroad

If the seller transports goods to a non-EU destination before the sale, the sale occurs outside France and is out of scope for e-reporting.

Buyer considerations

Inbound acquisitions

Produce Flow 10.1 with reverse-charged VAT at French rates.

Required data

Only header-level data required for acquisitions (no line detail).

E-reporting

No payment e-reporting required for acquisitions (Article 290 A).

Reverse charge rate and category

You must determine the correct reverse charge rate and category (K for intra-EU goods, AE for services).

General considerations

• The header parameter must indicate that the submission is for e-reporting when submitting B2B international data.

• Sovos validates the e-reporting data and transmits it to the PPF (passthrough).

• Flow 10 submissions must respect e-reporting periods per the taxpayer VAT regime.

• Late invoices (date before the period starts) are acceptable in Flow 10 if they correspond to the VAT declaration for that period.

Note:

E-reporting for B2B international is available as a passthrough service. You produce the e-reporting data (Flow 10.1 or 10.2) and submit it to Sovos, which validates and transmits it to the PPF. You must set the appropriate header parameter to indicate the submission is for e-reporting. With the upcoming consolidation feature, Sovos will support the aggregation of e-reporting records into periodic messages.

Sovos Canonical Invoice (SCI) mapping

Use case 43 primarily involves e-reporting (Flow 10.1 or 10.2) rather than the standard invoice exchange. Sovos does not process B2B international invoices through its platform for Flow 10.1 extraction. E-reporting data fields for your reference when building Flow 10.1 records:

Field	SCI path
BT-21/22 BAR note	Invoice/Note (with subject code BAR)
BT-118 VAT category	Invoice/TaxTotal/TaxSubtotal/TaxCategory/ID
BT-121 VATEX code	Invoice/TaxTotal/TaxSubtotal/TaxCategory/TaxExemptionReasonCode

Use case 43a: Triangular transactions

Three actors in three EU member states: seller A (country A) sells goods to intermediary B (country B), who resells to buyer C (country C). Goods ship directly from A to C. Under the simplification measure (Directive 2006/112/CE article 141, which ViDA recently updated), B does not need to register for VAT in country C.

Invoice and e-reporting specifics

A to B

Intra-community supply (K, VATEX-EU-IC). If A is in France, e-reporting B2B international sale.

B to C

Intra-community supply with reverse charge by C. Category AE, VATEX-EU-AE, with a reference to "Reverse charge – Article 141 of Directive 2006/112/EC – Triangular transaction." A dedicated VATEX code such as VATEX-EU-AE141 may be introduced through the ViDA implementation.

B is in France

In that case, there is no acquisition or sale e-reporting by B because there is no VAT obligation in France for this type of transaction.

C is in France

In that case, there is acquisition e-reporting with reverse-charged VAT (AE, VATEX-EU-AE).

Use case 43b: Intra-EU stock transfers

When a company transfers stock between two EU member states, this is treated as an intra-community supply for VAT purposes, even without a formal invoice. The supporting document may be a proforma invoice (BT-3=325, out of scope for the reform). The proforma number can be used as the invoice number in Flow 10.1 (TT-19), with document type code TT-21=380 to pass PPF validation.

Stock transfer from France to EU

Field	Value
TT-33 Seller ID	SIREN of the French entity (same entity)
TT-34 Seller VAT	French VAT number
TT-37 Buyer ID	SIREN of the same entity (self-supply)
TT-38 Buyer VAT	VAT number of the entity in the destination country
VAT category	K, VATEX-EU-IC (intra-community supply)
TT-52 VAT	0 (no VAT on outbound transfer)

Stock transfer to France from EU

Field	Value
TT-33 Seller ID	SIREN of the French entity
TT-34 Seller VAT	VAT number in the origin country
TT-37 Buyer ID	SIREN of the same entity
TT-38 Buyer VAT	French VAT number
VAT category	AE, VATEX-EU-AE (reverse charge)
TT-52 VAT	Reverse-charged VAT amount in EUR

Note:

Stock transfers to non-EU territories (including Group 2 DROM/COM/TAAF) do not require Flow 10.1 e-reporting. The transfer is outside the reform's scope.