France has implemented comprehensive VAT reforms affecting cross-border trade operations, eliminating fiscal representation requirements for non-EU importers and introducing mandatory electronic compliance measures under the EU's ViDA directive through 2030.
Elimination of Fiscal Representation
The 2024 Finance Act eliminated the punctual fiscal representative regime for non-EU companies importing goods under customs procedure 42 (duty-free circulation followed by intra-Community supply), effective January 1, 2026. Companies that initiated registration procedures before December 31, 2025 may continue using punctual fiscal representatives until obtaining French VAT numbers. Non-EU importers must now either appoint permanent fiscal representatives under Article 289 A, I of the Tax Code or obtain direct French VAT registration.
A new import agent regime introduced under Article 289 A bis permits foreign companies to delegate specific VAT formalities for limited operations, excluding customs procedure 42 imports. This regime will be abolished September 1, 2026 when the new Services and Goods Tax Code (CIBS) takes effect.
ViDA Implementation Timeline
The ViDA directive (EU 2025/516) establishes a phased modernisation of EU VAT systems through 2035. Key dates include July 1, 2028 for generalised OSS extension to all B2C supplies and stock transfers; January 1, 2030 for mandatory deemed supplier regimes for digital platforms covering accommodation and passenger transport; July 1, 2030 for mandatory structured e-invoicing and real-time e-reporting for all intra-Community B2B transactions, replacing current summary declarations.
French companies face coordinated compliance requirements as national e-invoicing obligations begin September 1, 2026 for large enterprises and September 1, 2027 for SMEs, aligning with the EU framework requiring harmonised systems by January 2035.
Transition to CIBS Code
Ordinance 2025-1247 transfers all VAT provisions from the General Tax Code to the new Services and Goods Tax Code effective September 1, 2026. The recodification maintains existing substantive rules while updating article numbering. Key provisions for goods supplies migrate from CGI articles 256, 258, 259, 262, 272, 289, and 291 to corresponding CIBS articles. Invoice references to former CGI provisions remain acceptable until December 31, 2027.
Context
These reforms represent France's most significant VAT modernisation in decades, eliminating administrative intermediaries while mandating direct digital compliance. The measures align French practice with EU digitalisation objectives and respond to cross-border e-commerce growth, positioning France as an early adopter of the EU's unified electronic VAT architecture scheduled for full implementation by 2035.
