The DES — the French filing nobody tells you about when you invoice EU clients
Invoicing an EU business client without VAT is not enough — France's European Declaration of Services is mandatory from the very first euro, with fines if you skip it.
Ever heard of the DES obligation? Neither had I, until recently.
I invoice a client based in the Netherlands. As expected for intra-community B2B, I invoice without VAT under the reverse-charge mechanism. Everything squeaky clean on the invoicing side.
Except one piece of the puzzle was missing: the European Declaration of Services (Déclaration Européenne de Services).
What is the DES?
The DES is a monthly declaration filed with French Customs (not the tax office) on pro.douane.gouv.fr, required as soon as you invoice a business client in another EU country.
- Mandatory from the very first euro. No threshold, no grace period.
- Must be filed before the 10th business day of the month following the invoice.
The penalties
- €750 per missing declaration.
- €1,500 after formal notice.
- €15 per omission or error.
The trap
The vicious part: it appears nowhere in your obligations when you register your business. Your accountant doesn't always think of it. You can go months — even years — without knowing, until the VIES cross-check on your EU client's side surfaces the problem.
The good news
In my case, I'll regularise the past months. Voluntary regularisation is possible and generally well received by the administration, as long as it happens before any audit.
If you invoice a German, Belgian, Dutch, Spanish, Italian or any other EU-based client, take 10 minutes to check you're compliant.
And if you're not, regularise.