Use case 44: Transactions with DROM, COM, and TAAF entities
Transactions involving entities in overseas territories, based on their fiscal group classification.
Description
This use case addresses how the French e-invoicing reform applies to transactions involving entities established in the Départements et Régions d'Outre-Mer (DROM), Collectivités d'Outre-Mer (COM), and Terres Australes et Antarctiques Françaises (TAAF). These territories are split into two fiscal groups that determine whether a transaction falls under domestic e-invoicing or international e-reporting.
- Group one - France (for VAT purposes)
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Metropolitan France (mainland)
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Guadeloupe (GP)
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Martinique (MQ)
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Réunion (RE)
Note:Transactions within group one are domestic and subject to e-invoicing (Flow 1). GP, MQ, and RE have specific VAT rates but are otherwise treated identically to Metropolitan France.
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- Group two - Export (outside VAT territory)
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French Guiana (GF)
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Mayotte (YT)
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All COM territories: French Polynesia (PF), New Caledonia (NC), Saint Barthélemy (BL), Saint Martin (MF), Saint Pierre and Miquelon (PM), Wallis and Futuna (WF).
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TAAF: French Southern Territories (TF).
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Transactions from group one to group two are treated as B2B international exports. Transactions from group two to group one may trigger acquisition e-reporting for the group one buyer (services) or are imports (goods, outside the e-reporting scope).
- Key characteristics
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- Group one to group one
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Domestic e-invoicing (Flow 1). Country code must be "FR" in Flow 1.
- Group one to group two
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Export: e-reporting B2B international sale (Flow 10.1) by the group one seller.
- Group two to group one (goods)
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Import: outside the e-reporting scope for the group one buyer.
- Group two to group one (services)
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Acquisition e-reporting (Flow 10.1) by the group one buyer.
- Group two to group two
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Seller is out of scope (unless Article 290 II applies).
- Sovos requirements
- Sovos requires invoices involving group one DROM entities (Guadeloupe, Martinique, Réunion) to use the country code "FR" because Flow 1 requires "FR" for all group one territories. Group two entities (Guiana, Mayotte, COM, and TAAF) must use their geographic ISO codes (for example, GF and YT) because these are used directly in Flow 10.1.
- Postal codes
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Postal codes identify the territory: 971=GP, 972=MQ, 973=GF, 974=RE, 976=YT.
- BR-FR-MAP-14
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This business rule covers country code mapping in Flow 1 and Flow 10.1.
- Relationship to other use cases
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Use case 44 applies use case 43's principles (B2B international e-reporting) to the specific French overseas territory context. The country code normalization challenge is unique to use case 44 and directly affects Flow 1 generation (BR-FR-MAP-14). B2C transactions from group one to group two customers follow the standard B2C e-reporting rules.
Business and tax context
- Legal and regulatory framework
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The tax classification derives from the Code Général des Impôts (CGI):
- Guadeloupe, Martinique, and Réunion
- Within the French VAT territory (with specific rates)
- Guiana, Mayotte, COM, and TAAF
- Excluded from the French VAT territory and treated as non-EU for VAT purposes.
Note:Article 290 I 1° covers e-reporting for sales from group one to group two. Article 290 II may apply to group two sellers with French VAT obligations.
- Common business scenarios
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- Metropolitan France to Guadeloupe (goods)
- Domestic e-invoicing (both group one).
- Metropolitan France to Guiana (goods)
- Export e-reporting B2B international (group one to group two).
- Polynesia to Réunion (services)
- Buyer does acquisition e-reporting (group two to group one services).
- Guadeloupe to Martinique (goods)
- Domestic e-invoicing (both group one, both FR).
- Guiana to Mayotte
- Seller out of scope (both group two, unless Article 290 II applies).
- Tax and accounting implications
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For group one DROM (Guadeloupe, Martinique, Réunion), Sovos requires you to submit invoices with the country code "FR". This is because Flow 1 requires "FR" for all group one territories, and submitting "FR" directly avoids the need for country code mapping on these invoices. For group two territories (Guiana, Mayotte, COM, TAAF), you must use the geographic ISO codes (GF, YT, and others) as these are the codes required in Flow 10.1.
Important:For group one DROM (Guadeloupe, Martinique, Réunion), you must submit invoices to Sovos with the country code "FR". For group two territories (Guiana, Mayotte, COM, TAAF), you must submit invoices with the geographic ISO code (GF, YT, PF, NC, BL, MF, PM, WF, or TF).
Key data requirements
| Territory | Customer submits | Flow 1 | Flow 10.1 |
|---|---|---|---|
| Metropolitan France | FR | FR (domestic) | N/A |
| Guadeloupe (group one) | FR | FR (domestic) | N/A |
| Martinique (group one) | FR | FR (domestic) | N/A |
| Réunion (group one) | FR | FR (domestic) | N/A |
| Guiana (group two) | GF | N/A (international) | GF |
| Mayotte (group two) | YT | N/A (international) | YT |
| COM or TAAF (group two) | PF, NC, BL, MF, PM, WF, or TF | N/A (international) | As submitted |
Implementation considerations
- Seller considerations
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- Group one DROM (Guadeloupe, Martinique, and Réunion)
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Submit invoices to Sovos with the country code "FR" for e-invoicing.
- Group two territories (Guiana, Mayotte, COM, and TAAF)
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Submit e-reporting data with the geographic ISO code (for example, GF and YT) and use the header parameter to indicate e-reporting.
- Buyer classification
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Determine whether the buyer is group one or group two to apply the correct treatment (e-invoicing versus e-reporting).
- Group one to group two sales
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Apply export VAT treatment (category G for goods, AE for services).
- Buyer considerations
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- Group one buyers (services)
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Group one buyers receiving services from group two sellers must produce acquisition e-reporting (Article 290-I-10°).
- Goods imports from group two
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These transactions are outside the e-reporting scope.
- General considerations
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Group one DROM invoices submitted as "FR" are processed as domestic e-invoicing (Flow 1).
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Group two submissions must use the geographic ISO codes (for example, GF and YT) and the header parameter indicating e-reporting.
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E-reporting for group two transactions is processed as passthrough: Sovos validates and transmits to the PPF.
Note:For group one DROM (Guadeloupe, Martinique, Réunion), submit invoices with country code "FR" for domestic e-invoicing. Sovos processes these as standard domestic invoices and generates Flow 1. For group two territories (Guiana, Mayotte, COM, TAAF), submit the e-reporting data with the geographic ISO codes (for example, GF and YT) and set the header parameter to indicate e-reporting. Sovos validates and transmits the e-reporting data to the PPF (passthrough). There is no automatic routing between e-invoicing and e-reporting: You must determine the processing path by choosing the submission type and the header parameter.
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- Sovos Canonical Invoice (SCI) mapping
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Standard SCI mappings apply for group one domestic invoices (country code "FR"). For group two e-reporting submissions, you must produce the e-reporting data directly. The header parameter determines whether a submission is processed as e-invoicing or e-reporting.
Field SCI path BT-40 Seller country Invoice/AccountingSupplierParty/Party/PostalAddress/Country/IdentificationCodeBT-55 Buyer country Invoice/AccountingCustomerParty/Party/PostalAddress/Country/IdentificationCodeBT-38 Seller postal zone Invoice/AccountingSupplierParty/Party/PostalAddress/PostalZoneBT-53 Buyer postal zone Invoice/AccountingCustomerParty/Party/PostalAddress/PostalZone
