Description

When a non-EU, non-taxable customer purchases goods in France, they may be eligible for a VAT refund (détaxe) upon export. The seller issues a Bulletin de Vente à l'Exportation (BVE), which the customer presents at customs upon departure. The refund must be claimed within six months. Three operational scenarios exist, each with different e-reporting implications:

Case 1

The seller initially declares the sale as domestic B2C (Flow 10.3, category TLB1). When the BVE is validated at customs, the seller corrects the B2C e-reporting from category TLB1 entry (negative amounts) to category TNT1, which is not subject to VAT in France.

Case 2

The seller directly declares the sale as international B2C (TNT1, no French VAT) but must reclassify to domestic (TLB1) if the BVE is not validated within six months.

Case 3

A tax refund operator handles the entire process, purchasing the goods from the seller (similar to use case 30, B7 mechanism) and managing the customs and refund process with the customer. Once the customer validates their tax refund, the seller issues a B2B invoice to the operator under billing framework B7, and the operator then reports the sale in Flow 10.3 under TNT1.

Key characteristics

Scope

Applies to B2C sales to non-EU, non-taxable customers.

BVE requirement

A BVE is required for customs validation, with a six-month deadline.

Case 1

B2C domestic declaration, then reclassification to TNT1 when the BVE is validated. This is the most common scenario.

Case 2

Direct international B2C (TNT1), then reclassification to TLB1 if the BVE is not validated within six months.

Case 3

A tax refund operator handles everything. The seller issues a B2B invoice to the operator under billing framework B7. The operator then reports the customer sale in Flow 10.3 under TNT1.

Commission

The seller's commission on the tax refund is a taxable service (B2C e-reporting or B2B e-invoicing).

Operator reimbursement

The tax refund operator's reimbursement to the seller is a disbursement (partially or fully outside scope).

Relationship to other use cases

Case 1 uses the e-reporting reclassification mechanism (negative and positive entries in Flow 10.3). Case 3 is similar to use case 30 (VAT already collected) when the seller issues a B2B invoice to the operator after initial B2C e-reporting. Use case 16 (reimbursements) applies to the operator's reimbursement invoice. The commission invoice follows standard e-invoicing or e-reporting, depending on the context.

Business and tax context

Legal and regulatory framework

Tax refunding is governed by Article 262 of the Code Général des Impôts (CGI). The BVE system is administered by customs. The six-month validation period is a hard deadline. Tax refund operators must be authorized and comply with customs regulations. The seller's commission on the tax refund is a taxable service under normal VAT rules.

Common business scenarios

Luxury retail

A tourist purchases designer goods and claims VAT refund at the airport.

Department stores

Department stores use dedicated tax refund counters with an operator-managed process.

Online-to-store

A non-EU customer orders online, picks up the order in a store, then claims a tax refund.

Tax and accounting implications

Case 1

The initial B2C domestic declaration includes VAT. Upon BVE validation, the seller must reclassify the sale and refund the VAT. This creates a negative entry in TLB1 and a positive entry in TNT1 in Flow 10.3.

Case 2

There is no initial VAT, but there is a risk of reclassification if the BVE is not validated.

Case 3

The seller's initial B2C domestic declaration (TLB1) is replaced by a B2B invoice to the tax refund operator under billing framework B7, with BT-113 (amount already paid) equal to BT-112 (total with VAT) and BT-115 (net amount payable) equal to 0. The operator then reports the customer sale in Flow 10.3 under TNT1, offsetting the VAT deductibility from the B2B purchase. The seller must post a reverse entry for the B2C sale replaced by this invoice.

Key data requirements

Case 1: Initial B2C declaration

Field ID	Description	Value
TT-81	Transaction category	TLB1 (domestic goods sale)
TT-82	Amount excluding tax (HT)	Sale amount excluding tax
TT-83	VAT amount	VAT collected
TG-32	Breakdown by VAT rate	TT-86 VAT rate TT-87 VAT base TT-88 VAT amount

Case 1: Reclassification after BVE validation

Field ID	Description	Value
TT-81 (cancel)	Transaction category	TLB1 (negative amounts)
TT-81 (new)	Transaction category	TNT1 (not subject to VAT in France, HT only, VAT is zero)

Case 2: Initial B2C declaration

Field ID	Description	Value
TT-81	Transaction category	TNT1 (not subject to VAT in France)
TT-82	Amount excluding tax (HT)	Total amount without VAT
TT-83	VAT amount	0
TG-32	Breakdown by VAT rate	TT-86 0 (VAT rate) TT-87 Total amount without VAT TT-88 0 (VAT amount)

Case 2: Reclassification to TLB1 if BVE not validated

Field ID	Description	Value
TT-81 (cancel)	Transaction category	TNT1 (negative amounts)
TT-81 (new)	Transaction category	TLB1 (domestic goods sale)
TT-82	Amount excluding tax (HT)	Sale amount / (1 + VAT rate / 100), rounded to 2 decimal places
TT-83	VAT amount	Initial sale amount minus TT-82
TG-32	Breakdown by VAT rate	TT-86 VAT rate TT-87 Equal to TT-82 TT-88 Equal to TT-83

Case 3: B2B invoice to tax refund operator

Field ID	Description	Value
BT-23	Billing framework (business process type)	B7 (invoice for VAT already declared in B2C e-reporting)
BT-113	Amount already paid	Equal to BT-112 (total with VAT)
BT-115	Net amount payable	0
BT-18 (optional)	Invoiced item identifier	BVE reference, with BT-18-1 qualifier equal to APT

Case 3: Operator Flow 10.3 e-reporting

Field ID	Description	Value
TT-81	Transaction category	TNT1 (not subject to VAT in France)
TT-82	Amount excluding tax (HT)	Total amount without VAT
TT-83	VAT amount	0
TG-32	Breakdown by VAT rate	TT-86 0 (VAT rate) TT-87 Total amount without VAT TT-88 0 (VAT amount)

Implementation considerations

Seller considerations

Case 1

Track BVE validation within six months for reclassification. Submit negative TLB1 and positive TNT1 in Flow 10.3 upon BVE validation.

Case 2

Track six-month deadline. Reclassify to TLB1 if the BVE is not validated.

Case 3

Issue B2B invoice to the operator under billing framework B7 once the customer validates the tax refund. Post a reverse entry for the B2C sale replaced by this invoice.

Tax refund commission

Declare as a taxable service (e-reporting B2C or e-invoicing B2B).

Buyer considerations

Non-EU customer

Present BVE at customs for validation within six months.

Tax refund operator

Process reimbursement and manage the customs interface. Report the customer sale in Flow 10.3 under TNT1 after reimbursing the VAT.

General considerations

• PA-E must support Flow 10.3 reclassification (negative and positive entries).

• The systems should track the BVE status and the six-month validation deadline.

• The systems should support automatic reclassification triggers upon BVE validation or expiry.

Note:

The tax refund operator requires coordination with the seller for invoice reclassification and with customs for BVE validation. The Sovos solution handles this through its user interface with role-based permissions, enabling tax refund operators to manage BVE validation, trigger e-reporting reclassifications, and coordinate reimbursement invoicing with sellers.

SCI mapping

• Use case 42 primarily involves e-reporting (Flow 10.3) rather than invoice formats.

• For case 3, when a B2B invoice is issued to the tax refund operator, standard SCI mappings apply based on use case 30, with BT-23 equal to B7.