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Use case 12: Transparent intermediary managing invoices for principal buyer

A transparent intermediary acts in the name and on behalf of the buyer to manage invoices, create lifecycle statuses, and share documents with the principal buyer.

Description

This use case covers the transparent intermediary who acts on behalf of the buyer in the negotiation of contracts and sourcing of suppliers. Under VAT law, the transparent intermediary acts in the name and on behalf of the principal. The intermediary appears as the principal's representative in relations with suppliers (BOI-TVA-CHAMP-10-10-40-40).

The key structural element is that the buyer creates an electronic invoicing address (for example, SIREN_GESTIONTIERS) whose management is entrusted to a Platform of the Transparent Intermediary (PA-TR). The intermediary gets invoices sent to this address, processes them on behalf of the buyer, creates lifecycle statuses, and shares the invoice and its lifecycle with the buyer.

Two invoices are involved in this arrangement: The main commercial invoice from the seller to the buyer (processed by the intermediary), and a separate entremise (commission) invoice from the intermediary to the buyer for the intermediation service itself. The entremise invoice follows the standard e-invoicing flow.

Key Characteristics
  • Intermediary acts in name and on behalf of buyer (transparent in VAT sense).

  • Buyer creates e-address (SIREN_GESTIONTIERS) managed by intermediary using PA-TR.

  • Intermediary processes invoices, creates statuses, and may handle payment for the buyer.

  • Buyer receives two invoices: Main commercial invoice and separate entremise (commission) invoice.

  • Intermediary shares invoice and lifecycle with buyer (using PA-TR or direct integration).

  • Intermediary may be delegated Payment Transmitted status creation.

  • Optional: Use EXT-FR-FE-BG-01 (Buyer Agent) or EXT-FR-FE-BG-04 (Addressed To) to identify the intermediary.

Relationship to other use cases
Use case 12 is a specific legal variant of use case 11 (Third-Party Processes for Buyer), where the agent is a transparent intermediary under VAT law. The intermediary's role is closer to an Agent d'Acheteur. Use case 19a (billing mandate) covers the mirror scenario where the intermediary acts for the seller. Use case 17b (marketplace with billing mandate) is also related when the marketplace acts as transparent intermediary for the seller.

Business and tax context

Legal and regulatory framework

Under BOI-TVA-CHAMP-10-10-40-40, the transparent intermediary acts for the account and in the name of the principal. Entremise operations are treated as independent service provisions subject to their own VAT regime. The entremise invoice must be issued separately and follows standard e-invoicing needs between two French-established taxable persons.

The principal buyer must keep access to all invoices for accounting purposes. The intermediary must have the proper authorization and technical setup to issue invoices and transmit invoice data on the principal's behalf.

Common business scenarios
Purchasing cooperative
Sources and negotiates with suppliers on behalf of members.
Travel management company
Manages business travel procurement for corporate clients.
Facility management
An agent manages supplier invoices for building maintenance.
Fleet management
An intermediary handles all vehicle-related supplier invoices for corporate fleet.
Tax and accounting implications

The buyer keeps all VAT deduction rights on the main commercial invoice. The entremise invoice has its own VAT treatment as a service provision. The intermediary does not have fiscal obligations related to the main invoice; these stay with the buyer.

The intermediary may prepare a summary document grouping multiple invoices for the buyer to help with payment.

Key data requirements

Field IDDescriptionValue
BT-3Invoice type code380 (Standard invoice)
BG-7Buyer blockBuyer (principal) identification
BT-49Buyer e-addressSIREN_GESTIONTIERS (managed by the intermediary)
EXT-FR-FE-BG-01Buyer agentIntermediary identification (optional)
EXT-FR-FE-BG-04Addressed toIntermediary identification (optional)

Implementation considerations

Seller considerations
  • Use the e-address given (SIREN_GESTIONTIERS); optionally use EXTENDED-CTC-FR for agent identification.

Buyer considerations
  • Set up the proper delegation framework with the intermediary.

  • Make sure you can access invoices and lifecycle data through PA-TR or direct replication.

  • Process and account for the entremise (commission) invoice separately.

General considerations
  • PA-TR must support delegation rights for intermediary to act on behalf of buyer.

  • PA-TR should support replication and sharing of invoices and lifecycle to buyer systems.

  • Optional: PA-TR may support summary document generation.

Note:

The transparent intermediary needs full invoice processing and status management capabilities on behalf of the principal buyer. The Sovos solution handles this through its interface with granular role-based permissions, letting intermediaries get, process, approve, and manage payment for invoices on dedicated addresses, while making sure the principal buyer keeps full visibility and accounting access to all documents and lifecycle events.

SCI mapping
FieldSCI path
BT-3 Invoice typeInvoice/InvoiceTypeCode
BG-4 SellerInvoice/AccountingSupplierParty/Party
BG-7 BuyerInvoice/AccountingCustomerParty/Party
BT-49 Buyer e-addressInvoice/AccountingCustomerParty/Party/EndpointID
EXT-FR-FE-BG-01 Buyer agentInvoice/AccountingCustomerParty/Party/AgentParty
EXT-FR-FE-BG-04 Addressed toInvoice/AccountingCustomerParty/Party/ServiceProviderParty/Party
BT-112 Total TTCInvoice/LegalMonetaryTotal/TaxInclusiveAmount
BT-115 Amount dueInvoice/LegalMonetaryTotal/PayableAmount