Subsidiaries of international groups: are you affected by electronic invoicing?
Abstract Electronic invoicing, also called X-Invoice, will apply to all companies. Subsidiaries of international groups must take advantage of this rule to streamline their processes & enhance productivity. Explanations
Reminder of the basis for the obligation to issue invoices in general
According to Article 289 of the French General Tax Code (CGI), the obligation to issue invoices arises from the independent performance of transactions relating to an economic activity. The status of taxable person is therefore independent of whether or not VAT is actually paid.
And… electronic invoices: general scope of application…
The electronic invoicing reform, which will take effect in September 2026, will apply to all companies, without exception, regardless of their turnover, legal form, or tax regime. In short, this definition of a taxable person is consistent with the obligation to invoice as defined in the previous paragraph.
And to subsidiaries of international groups
They will therefore be subject to the obligation to issue electronic invoices, like any company, like any economic agent identified by a Siret number. Subsidiaries whose turnover is generated solely with group companies located outside France, and therefore exempt from VAT, are affected by the electronic invoicing reform.
In practical terms, what are the consequences for subsidiaries of international groups?
They must join an approved platform (PA) before September 1, 2026.
This membership is necessary so that the suppliers of these subsidiaries, who are themselves subject to VAT, can meet their own electronic invoicing obligations.
These subsidiaries are advised to contact their accountant if he or she keeps their accounts.
In practical terms, once they have joined the approved platform (PA).
They will automatically receive invoices from their suppliers in electronic format, (i) gradually until September1, 2027, (ii) then in full, without exception, from that date onwards.
Are they required to send their customer invoices electronically as of September 1, 2027?
Only if their turnover is subject to French VAT. Subsidiaries whose turnover is completely exempt from VAT are exempt from this requirement to send customer invoices electronically.
What are the benefits of e-invoicing…
Subsidiaries of international groups should view electronic invoicing not as a constraint, but as a unique opportunity to transform business processes, in short, to streamline them. In fact, it will ultimately lead to the quasi-automatic processing of customer and supplier invoices, reducing disputes and payment delays.
For small subsidiaries of international groups, whose processes are generally simple and integrated, X invoicing requires minor adjustments that do not necessitate a complete overhaul.
Under these conditions, it is advisable for them to join a platform at the beginning of 2026.
For large subsidiaries of international groups, the electronic invoice reform is a transformational, change management project that requires the involvement of all stakeholders to avoid the risk of disorganisation or penalties (see below). Under these conditions, rewriting and then validating processes are a prerequisite for joining the approval platform.
… and penalties for non-compliance?
Like any economic agent with a SIRET number, they are liable to two fines: first, (i) for non-compliance (€500 after a formal notice has remained without effect, then €1,000 per quarter of non-compliance) and second, (ii) €50 per invoice not transmitted electronically. The penalties will likely be increased in the future.
Subsidiaries of international groups and electronic invoicing reform: summary
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