dac7 2024.2.2

Tooling for DAC7

DAC7 (France report for 2024 earnings)

[!CAUTION] All content shared in this repository is provided "as is" without any warranty of any kind from its authors. Users are responsible for verifying their own compliance with DAC7 obligations.

Quick-start

poetry install

# Build a XML declaration from dedicated JSON files
dac7 build -E PROD -f XML \
                      -p platform_operator.json \
                      -o other_platform_operators.json \
                      -e entity_sellers.json \
                      -i individual_sellers.json \
                      > declaration.xml

# Rename the file according to the specification
filename=$(dac7 name declaration.xml)
mv declaration.xml ${filename}

# Validate a XML declaration, both name and content
dac7 validate ${filename}

# Compress and encrypt. Require GnuPG to be installed
dac7 encrypt -z -E PROD ${filename} > ${filename}.gz.gpg

Contents of the repository

This repository is focused on the French version of DAC7, the requirements of which have been published by the Direction générale des Finances publiques, or DGFiP, on October 24, 2024 (cahier des charges v1.4, schema v1.1 :fr:). They differ from the original OECD standard on a couple of points that are small yet enough to break compatibility (see below).

[!NOTE] Please open an issue, or even better a PR, if you would like to extend this repository to cover other tax authorities.

This repository contains:

• a revised XSD schema based on one released by DGFiP, implementing additional checks
• a Python CLI to build an XML declaration and encrypt it according to the DGFiP requirements

Revised XML schema

The DGFiP specification :fr: is not compatible with the OECD standard v1 on at least the following points:

• The URIs for the XML namespaces dpi and stf ends with :v1 in the OECD schema and not in the DGFiP schema
• The DGFiP schema uses TaxesQn elements instead of the TaxQn required by the OECD schema

For this reason, the French tax authority has provided its own XSD schema. Unfortunately, its version v1.1 :fr: does not implement all the requirements stated in the specification document :fr: released at the same time.

For this reason, we provide a revised version of the French schema in the schemas/xml folder that includes the following additional checks:

1. The version attribute of the <dpi:DPI_OECD> element is mandatory, and its value must be 1.0, even in the version v1.1 of the DGFiP schema
2. The value in a <dpi:MessageRefId> element must have between 1 and 88 characters and contain the SIREN of the platform
3. The value in a <ConsQn>, <NumbQn>, <FeesQn>, or <TaxesQn> element must be greater or equal to zero
4. The value in a <dpi:ResCountryCode> element must be a country covered by DAC7, i.e. within the EU

Those schemas are adapted from the schemas included in the DGFiP specification documents (Cahier des charges DPI-DAC7), which are published under the Etalab-2.0 license.

Python CLI

This repository also includes a Python CLI dac7 that can be used to:

• Encrypt a French DAC7 declaration using the DGFiP keys
• Get the name an XML declaration should have to match the naming convention :fr: issued by DGFiP
• Check the conformity of an XML declaration with both the revised schema and the naming convention
• Build an XML declaration from dedicated flat JSON files:
  • A file for the main digital platform information
  • A file for the entity sellers
  • A file for the individual sellers
  • If applicable, a file for the platform assuming the declaration in place of the main platform, or the platforms whose declaration is assumed by it

The corresponding JSON schemas are included in the schemas/json folder.

How-To

Install and prerequisites

To run the dac7 CLI, you need:

• Python 3.11 or 3.12 or 3.13
• GnuPG, if you want to encrypt the declaration file

It may work with other versions, maybe. Don't hesitate to open a PR to update the documentation and/or the code!

pipx install dac7

Then you can explore all the available dac7 commands with

dac7 --help

Compress and encrypt an XML declaration

[!NOTE] You need GnuPG to be installed on your system to be able to encrypt the file

The DGFiP test and prod platforms expect a compressed-then-encrypted file, using the corresponding test and prod encryption keys.

The encrypt command can do both in one go:

dac7 encrypt -z -E PROD declaration.xml > declaration.xml.gz.gpg

Or, for a test file,

dac7 encrypt -z -E TEST declaration.xml > declaration.xml.gz.gpg

To get more help,

dac7 encrypt --help

Validate an XML declaration

To check both the content of the file and its name,

dac7 validate declaration.xml

To get more help,

dac7 validate --help

Get the expected name of an XML declaration file

If you already have a file declaration.xml, you can get the name it should have to match the DGFiP naming convention :fr: with

dac7 name declaration.xml

Build an XML declaration from dedicated flat JSON files

The DAC7 schema is not always very practicable. It is indeed very nested: for instance, the <dpi:Address> element contains the country code in a <dpi:CountryCode> element and the rest of the address in <dpi:AddressFix>. When the data comes flat from a relational database, nesting it the right way is cumbersome.

Furthermore, a DAC7 declaration mixes different elements in one file:

• The platform operator data, which is small and almost never changes
• Entity sellers, which are companies and require specific information
• Individual sellers, which require very different information

We propose to split those elements between different flat JSON files, and then assemble them together to produce the expected XML file:

dac7 build -E PROD -f XML \
                      -p platform_operator.json \
                      [-o other_platform_operators.json] \
                      [-e entity_sellers.json] \
                      [-i individual_sellers.json] \
                      > declaration.xml

Compared to the XML validation performed by dac7 validate, some additional 2nd-level validation rules from the DGFiP specification are performed when using dac7 build:

• Rule 2: one quarterly consideration is less than zero, or a seller's overall consideration is zero
• Rule 12: the birthplace of an individual seller is mandatory if they don't have a Tax Identification Number
• Rule 33: any seller needs to report at least one relevant activity
• Rule 34-1 and 34-2: a NOTIN value is not allowed for a platform or seller among other proper Tax Identification Numbers

To get more help,

dac7 build --help

To get the JSON schemas for each of the input files,

dac7 schemas build --help

Examples

In the examples folder, we provide files adapted from the examples included in the DGFiP specification documents (Cahier des charges DPI-DAC7), which are published under the Etalab-2.0 license.

1. Entity and individual sellers for immovable properties

Example 1 is an initial declaration for a platform operator with one entity seller and one individual seller, both for immovable properties.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/1_initial_immovable_properties/input/platform_operator.json \
   -e examples/1_initial_immovable_properties/input/entity_sellers.json \
   -i examples/1_initial_immovable_properties/input/individual_sellers.json \
   > declaration.xml

2. Entity and individual sellers for sale of goods

Example 2 is an initial declaration for a platform operator with two entity sellers and one individual sellers, all for the sale of goods.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/2_initial_sale_of_goods/input/platform_operator.json \
   -e examples/2_initial_sale_of_goods/input/entity_sellers.json \
   -i examples/2_initial_sale_of_goods/input/individual_sellers.json \
   > declaration.xml

3. Additional individual seller

Example 3 is an additional declaration for one individual seller that was missing from the initial declaration.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/3_additional/input/platform_operator.json \
   -i examples/3_additional/input/individual_sellers.json \
   > declaration.xml

4. Correction for platform operator and individual seller

Example 4 is a corrective declaration for both the platform operator and one individual seller.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/4_corrective/input/platform_operator.json \
   -i examples/4_corrective/input/individual_sellers.json \
   > declaration.xml

5. Platform operator assuming the declaration of another

Example 5 is the initial declaration for a platform operator with individual sellers, that also assumes the declaration of another operator.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/5_initial_assuming/input/platform_operator.json \
   -o examples/5_initial_assuming/input/other_platform_operators.json \
   -i examples/5_initial_assuming/input/individual_sellers.json \
   > declaration.xml

6. Platform operator assumed by another

Example 6 is the initial declaration for a platform operator whose declaration is assumed by another operator.

You can rebuild the XML declaration with

dac7 build -E PROD \
   -p examples/6_initial_assumed/input/platform_operator.json \
   -o examples/6_initial_assumed/input/other_platform_operators.json \
   > declaration.xml

Development

PRs are welcome! But please take notice of the code of conduct.

Use the make command to set up your local environment and run the tests:

# Creates the virtual environment with poetry
# Install the project and all the dependencies
# Configure the pre-commit hook
make init

# Run all the tests
make test

# Regenerate the schemas
make schemas

Links

• Original DPI Schema (v1.0) published by the OECD
• Directive 2021/514 of March 22, 2021 amending Directive 2011/16 of February 15, 2011 (consolidated)
• Regulation 2022/1467 of September 5, 2022 amending Regulation 2015/2378 of December 15, 2015 (consolidated), which includes the OECD schema
• French specification for DPI-DAC7 data transfer :fr: published by DGFiP, which includes
  • a human-readable specification document
  • a schema for the content of the XML file
  • a "naming convention" for the file