Description

A debit note is a document issued by a seller to a buyer showing an amount owed. A debit note is not an invoice under the French tax law. It does not enter the scope of mandatory e-invoicing and does not require Flow 1 transmission or e-reporting.

However, if a debit note has all required invoice mentions and is subject to VAT, it must be treated as an invoice (BT-3=380) and follow the standard e-invoicing flow. This applies notably to re-invoicing within joint ventures (societes en participation). Similarly, if a debit note is issued by the buyer and represents a debt of the seller, the seller should issue a credit note instead, or the buyer can issue a self-billed credit note (BT-3=261) if a billing mandate exists.

Key characteristics

• Pure debit notes are not invoices and are outside the e-invoicing scope.

• No Flow 1 or e-reporting is required for pure debit notes.

• Debit notes with all required mentions and VAT qualify as invoices (BT-3=380) and fall within scope.

• A buyer-issued debit note representing seller debt becomes a self-billed credit note (BT-3=261).

• Pure debit notes can be exchanged through platforms voluntarily, but there is no regulatory obligation.

• If the buyer accepts the debit note, a proper invoice should be issued.

Relationship to other use cases

Use case 18 is primarily a clarification use case that defines what falls inside and outside the e-invoicing scope. When a debit note qualifies as an invoice, standard e-invoicing applies. When it becomes a self-billed credit note, use case 19b (Self-Billing) applies. The concept is relevant to use case 37 (Societes en Participation) where re-invoicing between members uses debit note-like instruments.

Business and tax context

Legal and regulatory framework

A debit note does not constitute an invoice under Article 289 of the CGI. It is a commercial document showing a debt. Only documents that meet all invoice requirements (mandatory mentions, VAT treatment, and chronological numbering) are treated as invoices subject to e-invoicing obligations.

Common business scenarios

Late payment penalties

Seller issues a debit note for interest charges.

Price adjustments

Debit note for contractual price increase.

Re-invoicing in partnerships

Cost sharing between joint venture members.

Damage claims

Debit note for contractual penalties.

Tax and accounting implications

Pure debit notes have no immediate VAT impact. If a proper invoice is later issued for the amount, standard VAT rules apply to that invoice. For debit notes that qualify as invoices (with VAT), all standard fiscal obligations apply.

Important: A debit note is not an invoice unless it has all required mentions and is subject to VAT. Pure debit notes are outside the e-invoicing scope. If a proper invoice is needed, it must be issued separately.

Key data requirements

For pure debit notes, there are no specific e-invoicing data requirements because they are outside the scope.

For debit notes that qualify as invoices:

Implementation considerations

Seller considerations

Determine whether a debit note qualifies as an invoice (all mandatory mentions and VAT).

If it qualifies

Use BT-3=380 and follow the standard e-invoicing flow.

If pure debit note

Exchange outside e-invoicing scope; issue proper invoice if accepted.

Buyer considerations

• If issuing a debit note representing seller debt, ask for a credit note from the seller or use a self-billed credit note (BT-3=261) with billing mandate.

General considerations

• Systems should distinguish between pure debit notes (outside scope) and invoice-qualifying debit notes.

SCI mapping

SCI mapping applies only when the debit note qualifies as an invoice (BT-3=380) or self-billed credit note (BT-3=261). Standard SCI invoice or credit note mappings apply in those cases.