A foreign-owned company can clear goods through France and still lose control of its cash position because customs data, the French VAT number and the accounting ledger do not identify the same legal entity. The risk is practical: a shipment may be released with the wrong importer, a customs broker may use an outdated EORI, or the import VAT amount may not appear correctly on the company’s CA3 return. In France, CA3 means the periodic French VAT return used by businesses under the normal VAT regime. Since 1 January 2022, import VAT has generally been declared through the VAT return by a business identified for French VAT, rather than paid as a separate cash advance at customs. That system can be cash-flow neutral when the company has a full right to deduct the tax, but it is not document-neutral. The importer, customs representative, VAT number, customs value and accounting evidence must line up. This article gives a foreign founder or group finance team a legal and operational checklist for the first French shipment, the EORI SIREN transition, the 1 September 2026 VAT recodification and a blocked or incorrectly prefilled CA3 return. It complements the firm’s French company formation and corporate law service and should be applied to the precise goods, route, contract and customs mandate.

I. How does import VAT work in France for a foreign-owned company?

A. When is a shipment an import, and who is responsible for the VAT?

The first question is not whether the shareholder is foreign. It is whether goods enter the French VAT territory from outside the European Union, or are released for consumption in France after a customs procedure. Article 291 of the French General Tax Code, or CGI (Code général des impôts), states in the current version applicable before the 1 September 2026 recodification: “Les importations de biens sont soumises à la taxe sur la valeur ajoutée.” The full Article 291 CGI then defines the relevant forms of importation and lists exemptions. A French subsidiary buying stock from its parent in the United States, a French branch receiving equipment from a non-European group company, and an overseas company using France as the first import destination may therefore be in materially different positions even if the invoice is issued by the same group.

Do not confuse a purchase from another European Union Member State with an import from a third country. Goods already released for free circulation in the European Union may move to France as an intra-Community acquisition, with a different VAT mechanism. Goods arriving from the United Kingdom, the United States, Switzerland, the United Arab Emirates or another non-EU territory normally require a customs declaration before they can be released in France. The route of the container, the customs procedure, the place of release and the identity of the party buying the goods must be mapped before the purchase order is signed.

The taxable event and the person liable for the tax must also be separated. Article 293 A CGI states: “A l’importation, le fait générateur se produit et la taxe devient exigible au moment où le bien est considéré comme importé”. Its full text links the import VAT event to the customs concept of importation and explains how the liable person is determined in different transaction models. For a standard shipment of goods purchased by a French company, the customs record and the commercial documents should identify that French company as the real recipient or transaction recipient, subject to the applicable customs representation and valuation rules. A freight forwarder, carrier or customs broker is not automatically the economic owner merely because it files the declaration.

The distinction matters when the foreign parent owns the goods until resale. A group may use a consignment, fulfilment, toll manufacturing, warehousing or commission structure. Under those models, the company named in the invoice, the company named as consignee, the company holding the stock and the company shown as importer may not be the same. The customs declaration must reflect the legal and commercial reality. A convenient name entered by a logistics provider can create an incorrect VAT liability, an unusable deduction position or a later dispute over a customs debt.

The customs representative’s mandate must be explicit. A direct representation arrangement generally means that the representative acts in the name and on behalf of the importer. An indirect representation arrangement means that the representative acts in its own name for another person and can carry joint liability under customs and VAT rules. The Cour de cassation decision of 11 February 2026, no. 24-18.748, ECLI:FR:CCASS:2026:CO00070, held that “la représentation en douanes doit être expresse et ne se présume pas”. For a foreign company, the customs power of attorney, the broker’s terms and the instruction on who is the importer should therefore be saved with the shipment file. A broker cannot safely infer a mode of representation from the existence of a foreign seller or from the fact that it paid the transport bill.

The same decision is a warning against treating the customs form as a technical formality. The Court criticised a lower court that had relied on presumptions to treat an EU-established declarant as acting indirectly for a United States exporter. The legal question was not solved by the exporter’s inability to act as a Union customs declarant. The mandate still had to be established. A foreign-owned French company should ask the broker to state, before the first shipment, the capacity in which it will act, the party responsible for customs debt, the party designated for import VAT and the documents that will be transmitted after clearance.

A second decision illustrates the exposure of a broker using a different representation model. In its 24 January 2024 decision, no. 21-17.776, ECLI:FR:CCASS:2024:CO00031, the commercial chamber held that the customs broker acting under an indirect representation mandate “bénéficie, en tant que débiteur de la TVA à l’importation, solidairement avec le redevable de cette taxe, de la dispense légale de caution”. The point is not that every broker becomes the taxpayer. The point is that the mandate can affect who is jointly liable and what security arrangements apply. The French company must not assume that an outsourced customs declaration removes its own exposure.

The 2026 decision also provides a recent caution about evidence. It concerned a dispute in which the exporter was a United States company and the customs declarant was established in the European Union. The Cour de cassation required more than an inference that a non-EU exporter must have authorised indirect representation. For a group importing through France, the file should contain the signed customs mandate, the broker’s acceptance, the invoice, the transport document, the packing list, the purchase order and the internal instruction identifying the importer. If the arrangement changes from direct to indirect representation, obtain a new mandate rather than allowing the change to occur silently in the broker’s system.

There is also a difference between the party liable for import VAT and the party entitled to deduct it. Article 271 CGI links deduction to the taxable business use of the goods. The official text states that, “Dans la mesure où les biens et les services sont utilisés pour les besoins de leurs opérations imposables”, the tax may be deductible when the other statutory conditions are met. The current Article 271 CGI version requires the VAT return data and import documents needed to establish the amount. A group entity that pays a supplier invoice but is not the importer, or that buys goods for an exempt activity, cannot create a deduction simply by booking the amount in its French ledger.

The Conseil d’État decision in Société Veleclair, 30 July 2010, no. 293478, is an important reference for import VAT deduction. The Court referred a question to the Court of Justice of the European Union and recorded the principle that “Il découle du b) du 1 du II de l’article 271 du code général des impôts que les redevables de la taxe sur la valeur ajoutée peuvent opérer la déduction de la taxe qui est perçue à l’importation.” The decision did not grant an unconditional deduction to every importer. It shows why liability, import documentation, taxable use and the applicable version of the law must be analysed together.

For a foreign-owned French company, ask four questions before the shipment is booked:

• Which legal entity buys the goods, owns them at importation and will use them for taxable French operations?
• Which entity is named in the customs declaration as importer, consignee or transaction recipient?
• Which customs representative is filing, under what express mandate and in which capacity?
• Which VAT and customs identifiers will appear in the declaration, the carrier’s system, the invoice and the CA3 reconciliation?

If the answers differ, stop the shipment instructions and resolve the mismatch. The fact that the foreign parent has a French VAT number, or that the French subsidiary has an EORI, does not by itself determine the correct importer. The transaction contract and customs facts control the analysis.

B. How do the French VAT number, EORI and customs value affect the CA3 amount?

A foreign-owned company generally needs two separate identification systems. The EORI means Economic Operator Registration and Identification: it identifies an economic operator in its customs relations with the authorities. The French VAT number, also called the French intra-Community VAT number, identifies the taxpayer for French VAT reporting. The SIREN is the nine-digit identifier of a French legal entity; the SIRET is the fourteen-digit identifier of a French establishment. They are not interchangeable. A French subsidiary may have one SIREN, several SIRET establishments, one French VAT number and a customs profile that is moving from an EORI SIRET to an EORI SIREN.

Article 286 ter CGI identifies the persons who must hold an individual VAT number. It expressly includes “tout assujetti redevable de la taxe sur la valeur ajoutée pour des importations”. Read the official Article 286 ter CGI page with its temporal notes, because the VAT recodification changes the code references from 1 September 2026. A company that intends to import through France but has no valid French intra-Community VAT number should contact the competent French tax service before the goods depart. A customs broker cannot cure a missing VAT registration by inserting its own number.

The French Customs Directorate, known as the DGDDI (Direction générale des douanes et des droits indirects), explains that an EORI is required before customs operations and that a request is made through the SOPRANO EORI service. SOPRANO is the French customs online platform used for certain applications and registrations. Its official EORI guide states that a business established in a third country may need French registration where it is not already registered in another European Union Member State. It also explains that an EORI is used in Delta G and Delta X, the electronic customs systems for import and export declarations.

The 2026 transition requires a separate validation. The French Customs Directorate’s 8 June 2026 France Sésame notice describes the move from EORI SIRET to EORI SIREN and the period during which both identifiers may appear in related systems. The notice says that the operator should request an authorisation based on the EORI SIREN during the transition. For a foreign-owned French company, the action is to verify the EORI in the customs database, the broker’s master data, the transport booking and any authorisation record. Do not infer that a valid old EORI SIRET has already migrated everywhere.

Then validate the VAT identifier on the customs declaration. The French Customs Directorate’s official import VAT self-assessment procedure states that, in Delta G or X Import, the French VAT number is entered with document code 1008, and in Delta H7 with the additional fiscal reference FR7. The import VAT is then collected and deducted through the CA3 when the company is within the relevant self-assessment system. The number must be the French VAT number of the liable entity, not the foreign parent’s local tax number and not the broker’s number.

Customs value is the second major input. Article 292 CGI states: “La base d’imposition est constituée par la valeur définie par la législation douanière”. Its official text adds import duties, taxes other than VAT and certain accessory costs up to the first destination in France or, where known at the taxable event, another destination in the European Union. The customs value is therefore not always identical to the supplier’s invoice total. Freight, insurance, commissions, royalties, assists, related-party pricing adjustments and destination information can affect the calculation.

Consider a simplified example. A French company imports machinery with a customs value of €100,000. Assume customs duty is €4,000 and transport and insurance included in the statutory import VAT base are €1,000. The illustrative VAT base is €105,000. At a 20% VAT rate, the import VAT is €21,000. If the French company uses the machinery for fully taxable operations, and if its CA3 data and documents are correct, the same €21,000 may appear as import VAT due and deductible. The example is not a tariff ruling: the duty rate, value adjustments, VAT rate, first destination, exemptions and special procedures must be verified for the actual goods.

A wrong customs value can create two different problems. An undervalue can cause a customs reassessment, interest, penalties and an additional VAT amount. An overvalue can create a cash or deduction distortion and may require a correction. The company should reconcile the customs value to the invoice and commercial ledger, but it should not change the customs value merely to make the CA3 amount match the purchase price. The customs declaration, not the accounting preference, is the starting evidence for the import VAT base.

Transfer pricing also requires care. A French subsidiary buying from a related foreign parent may use a year-end price adjustment, a resale-minus price or a cost-plus method. A later credit note or debit note may require a customs and VAT analysis. The accounting entry does not automatically amend a customs declaration, and a customs correction does not automatically settle the group’s transfer-pricing position. Preserve the intercompany agreement, pricing policy, invoice, customs valuation method, adjustment calculation and advice received.

The French public finance administration, known as the DGFiP (Direction générale des finances publiques), confirms that import VAT for a business identified in France is reported with the VAT return. Its official international-business VAT page explains that management and collection were transferred to the DGFiP on 1 January 2022 and that the import VAT self-assessment is mandatory for a person liable for French VAT. The same page distinguishes import transactions from exports and intra-Community transactions. This is why a foreign parent’s VAT treatment in its home country does not answer the French CA3 question.

For each shipment, assemble a data key that connects:

Data point	What to match	Why it matters
Legal entity	Company name, SIREN, registered address and group role	Identifies the taxpayer, importer and accounting owner.
VAT identity	Valid French VAT number and the entity’s VAT reporting account	Routes import VAT to the correct CA3 return.
Customs identity	EORI SIREN or other valid EORI, broker profile and declaration data	Permits clearance and avoids a stale establishment identifier.
Transaction	Supplier, purchaser, owner, consignee, Incoterm and destination	Supports the liable-person and customs-value analysis.
Evidence	Customs declaration, import reference, base and documents from the broker	Supports deduction, correction and audit responses.

Use the exact customs declaration reference in the accounting reconciliation. A carrier’s invoice for clearance fees is not the import declaration. A supplier invoice is not proof of the import VAT base. A CA3 prefill is not a substitute for the underlying customs data. The foreign finance team should receive both the customs document and the detailed import data feed before closing the reporting period.

The 1 September 2026 recodification adds a timing issue. Ordinance no. 2025-1247 of 17 December 2025 reorganises VAT provisions in the Code des impositions sur les biens et services, or CIBS (Code of Impositions on Goods and Services). The official ordinance and its transitional provisions must be read with the applicable date. The future Article L. 215-14 CIBS provides, for the version entering into force on 1 September 2026, that an assujetti or non-taxable legal person can be liable for import tax where the statutory conditions concerning inputs and an option are met. The new Articles L. 215-13 to L. 215-17 CIBS reorganise the general import-liability rules, including the transaction recipient and customs debtor.

Do not copy a new article number into a broker instruction without checking its effective date and the transaction category. The old Article 1695 CGI remains relevant to the transition before 1 September 2026. It states that “La taxe sur la valeur ajoutée est déclarée et perçue lorsqu’elle devient exigible” for the situations covered by its current wording. The official Article 1695 page records the scheduled abrogation and the transitional maintenance of some provisions. Finance teams should update their legal references and system mapping, but should not assume that a recodification alone changes the commercial importer.

II. How can a foreign-owned French company self-account for import VAT without a cash advance?

A. How should the company file the CA3 return and reconcile the customs declaration?

Self-assessment does not mean that no tax is declared. It means that the import VAT is brought into the French VAT return instead of being paid as a separate import charge at clearance, subject to the company’s status and the transaction’s treatment. The French Customs Directorate states that the system collects and deducts import VAT simultaneously on the CA3, without a cash advance, for businesses in the relevant French VAT regime. That neutral result depends on a full right to deduct and accurate reporting. If the goods are used for exempt activity, private use, a non-deductible activity or a mixed activity, the result may not be neutral.

Article 287 CGI imposes the reporting obligation. It provides that “Tout redevable de la taxe sur la valeur ajoutée identifié conformément aux dispositions combinées des articles 286 ter et 286 ter A est tenu de remettre au service des impôts dont il dépend” a prescribed return within the required deadline. The official Article 287 text states that businesses under the normal real-tax regime file monthly returns showing their operations and the tax due, with specific rules for other regimes. A foreign-owned company should confirm its actual filing frequency with its tax service; the frequency cannot be chosen merely because the parent’s home-country return is quarterly.

The Customs Directorate’s procedure also states that the VAT return is prefilled from information declared to customs, with a prefill made available on the fourteenth day of the month, and that the VAT return deadline is set on the twenty-fourth of the month for persons liable for import VAT under the described system. The official guidance identifies the SIE, meaning Service des impôts des entreprises or business tax service, and the DGE, meaning Direction des grandes entreprises or large-business directorate, as the relevant tax contacts. These dates should be checked against the company’s tax account and filing calendar, especially where a return is quarterly or a public holiday affects the electronic process.

The first monthly reconciliation should be performed in four stages. First, download the detailed customs import data available through the French tax or customs account for the period. Secondly, compare each customs declaration reference with the broker’s statement, the goods-received record and the general ledger. Thirdly, reconcile the taxable base and calculated import VAT to the amount shown on the CA3 prefill. Fourthly, verify the deductible amount against the actual business use and maintain a review note where the deduction is partial or deferred.

A practical reconciliation file should contain at least:

• the declaration reference, date of release and customs office;
• the importer’s legal name, French VAT number and EORI used;
• the customs value, duties, accessory costs and VAT base;
• the import VAT amount reported as tax due and the amount treated as deductible;
• the supplier invoice, transport document, packing list and customs mandate;
• the CA3 reporting period, accounting journal entry and reviewer’s sign-off; and
• any correction, customs message, broker credit note or tax-service correspondence.

Article 271 is important where the broker provides a document rather than a conventional VAT invoice. The article allows the deduction to be supported, for imports, by the import declaration or documents that state the declaration number, date and taxable base established through the customs reporting process. The statutory text refers to “soit la déclaration d’importation, soit les documents mentionnant le numéro, la date de cette déclaration et la base imposable”. Keep the document in a form that can be read and linked to the CA3 line. A screenshot showing a total without the declaration references may be inadequate during an audit.

The no-cash-advance benefit should be modelled rather than assumed. If the example import VAT is €21,000 and the company is fully entitled to deduct it, the CA3 may show €21,000 as import VAT collected or due and €21,000 as deductible import VAT. The net effect is zero before other VAT items. If the company can deduct only 60%, the immediate deductible amount may be €12,600 and €8,400 may remain a cost or require further analysis. If the company’s French VAT number was invalid on the declaration, the prefill may be absent or incorrect even if the goods were released.

Do not offset a missing prefill by inventing a number. The correct response is to compare the customs declaration with the detailed import data, identify whether the VAT number, EORI, declaration date or reporting period is wrong, and contact the SIE or DGE or the customs service as appropriate. Keep a written explanation of the correction. If the company adds the tax manually, it should record the statutory and documentary basis and avoid duplicating a later prefill.

The French Customs Directorate makes the data service available so that a taxpayer can check the amount prefilled on its VAT return. The service is particularly useful for a foreign group whose accounting system receives broker data from several ports or customs offices. Create a monthly control that flags:

Exception	Likely cause	Immediate action
Declaration absent from CA3 data	Wrong VAT number, late transmission or import recorded in another entity’s account	Check the declaration and VAT identifier; ask the tax or customs contact for the data path.
Base differs from ledger	Duty, freight, insurance, valuation adjustment or first destination omitted	Rebuild the customs base from Article 292 and the declaration, then document the variance.
VAT appears twice	Manual journal entry plus automatic prefill, or broker invoice treated as VAT	Match by declaration reference and reverse only the duplicate entry.
Deduction exceeds taxable use	Mixed or exempt activity, missing allocation key or goods not received	Apply the correct deduction rule and retain the allocation evidence.
Broker asks for VAT payment at clearance	Wrong representation, no valid French VAT identity or a special procedure	Do not assume the demand is wrong; verify the company’s status and the declaration model before payment.

The table also helps separate import VAT from the broker’s own charges. A customs broker may invoice brokerage, transport, storage, disbursements or a service VAT charge. Those amounts are not automatically the import VAT assessed on the goods. Book each component according to its own document and tax treatment. If the broker paid import VAT on behalf of a party under a special arrangement, obtain the customs declaration and establish whether the French company is the liable importer and the person entitled to deduct.

A group with a foreign parent should decide who owns the monthly control. The French statutory accountant, the internal finance team and the customs broker may each hold only part of the record. The French company remains responsible for the accuracy of its VAT return. The parent can provide funding and systems, but it should not let a group-level purchase ledger replace the French entity’s customs and VAT reconciliation.

The new CIBS provisions also reinforce the importance of pre-arrival data. Article L. 216-24 CIBS is scheduled to enter into force on 1 September 2026 and states: “Toute importation donne lieu à la communication préalable à l’administration des éléments relatifs à l’identification du redevable et aux caractéristiques de l’opération”. The official Article L. 216-24 page contains the recodified text and its effective-date information. The operational lesson is simple: identify the liable entity and the characteristics of the shipment before the declaration is lodged, not after the prefilled CA3 is already wrong.

B. What should the company do when the VAT number, EORI or shipment is wrong?

When a declaration is blocked, classify the problem before asking the broker to “try again”. The first category is identity: the company name, SIREN, SIRET, EORI or VAT number does not match the customs database. The second category is authority: the broker’s mandate is absent, expired or does not state direct or indirect representation. The third category is classification or value: the commodity code, origin, customs value, duty, Incoterm or destination information is incomplete or inaccurate. The fourth category is VAT reporting: the import is valid, but the CA3 prefill, reporting period or deduction entry is wrong.

For an identity mismatch, compare the exact legal name and registered address used in the French VAT account, the EORI record, the carrier’s master data and the customs declaration. Accents, punctuation, legal-form abbreviations and a former name can cause an automated match to fail. The French company should provide its current Kbis, the official extract of the company’s registration details, only through the secure channel requested by the broker or authority. It should not circulate a director’s passport or group documents unnecessarily.

For a French company, verify whether the EORI SIREN is active and whether the system still presents an EORI SIRET for a specific establishment. The Customs Directorate’s EORI page says that an EORI is mandatory before customs operations and that an EORI delivered by the French service becomes active after the administrative processing period stated by that service. Its official validation service also warns that EORI registration is free and that payment-demand websites may be fraudulent. Use the official validation route and record the result with the date and identifier checked.

For a company established in a country outside the European Union, confirm whether it already holds an EORI issued by another Member State. The Customs Directorate’s guidance distinguishes operators established in France, in another Member State and in a third country. A second French EORI application can create a duplicate or a routing error if the company is already registered elsewhere. The correct solution may be to use the existing Union EORI, to request a French EORI through SOPRANO or to appoint an eligible customs representative, depending on the operation and the applicable rule.

For a VAT identity mismatch, contact the French tax service before the next declaration. The Customs Directorate expressly states that a business without a valid French intra-Community VAT number that wishes to import in France must contact the competent tax services to obtain one and then use it on all customs declarations. A foreign parent should not lend its VAT number to a French subsidiary. A French subsidiary should not use the number of a branch, warehouse operator or broker unless the legal basis is documented.

If the shipment has been released with an incorrect VAT number, preserve the declaration as filed and ask the broker for the amendment procedure. Do not delete the original record from the accounting system. The corrected declaration, the amendment request, the reason for correction and the resulting import data should all be linked to the original reference. A correction to the customs declaration may affect duty and VAT and may require a CA3 adjustment. The finance team should avoid making a second manual entry until it knows whether the corrected amount will be transmitted automatically.

If the broker has entered indirect representation without a signed mandate, challenge the assumption promptly and ask which legal basis was used. The Cour de cassation’s no. 24-18.748 decision is a recent reminder that representation cannot be presumed. If the broker is using its own name for the company’s account, check the joint-liability consequences and the documents it must provide. If the broker is acting directly, check that the declaration still names the correct importer and contains the correct French VAT number.

Incorrect customs value requires a commercial and legal reconstruction. Gather the purchase order, invoice, payment proof, transport and insurance documents, commissions, royalties, assists, related-party agreement and the goods’ first destination. Check the classification and origin separately. Use the French customs tariff database RITA, meaning Référentiel intégré tarifaire automatisé, where appropriate, to verify the duty and tax treatment of the product. Do not use a generic internet tariff calculator as the sole basis for a customs declaration.

A customs reassessment can create a second import VAT entry. Suppose the customs authority adds €10,000 to the taxable base and the applicable VAT rate is 20%. The additional import VAT would be €2,000, subject to the actual decision and any right to deduct. The company should book the reassessment by reference to the customs decision and the corrected declaration. It should not treat a broker’s debit note as the legal assessment without obtaining the official customs evidence.

If the company’s goods are not used entirely for taxable operations, calculate the deduction separately. A machine used for taxable sales and exempt financial services, goods supplied free of charge, samples, private use or activities outside the French VAT scope may require an allocation or adjustment. Article 271’s taxable-use condition remains the legal starting point. Keep the allocation key, board or finance approval, asset register, sales activity and any later adjustment. A foreign parent’s instruction to deduct the full amount does not override the French rule.

When the CA3 prefill is missing, first check timing. Import data may be transmitted after the declaration is accepted, and the company may be reviewing the wrong month. Next check the VAT number and declaration reference. Then compare the detailed customs data with the tax account. If the amount remains absent or wrong, document the contact with the SIE or DGE and the customs office. The response should state the declaration number, date, importer, VAT number, base, VAT amount, reporting period and requested correction. A vague request that “VAT is not showing” is difficult to trace.

When the CA3 contains a duplicate, the company should determine whether one line is an automatic import-VAT entry and the other is a domestic broker-service VAT entry. The invoices and customs declaration are different evidence. If it is a true duplicate, reverse the manual or duplicate entry with an audit trail. If the company already filed an incorrect return, ask its tax adviser or tax service how to correct the return. Do not silently alter a closed VAT period in the ledger without preserving the original filing and correction.

A foreign founder may receive a customs or tax notice at the registered office while living abroad. The company’s legal representative should ensure that official notices reach the person who controls the customs and VAT file. A registered-office provider, accounting firm or broker may receive mail without authority to decide the response. Set an internal escalation rule: same-day scanning, two-person review, deadline calendar, document preservation and a decision on whether to pay, contest, correct or request more time.

Where customs penalties or a tax reassessment are contemplated, prepare a chronology. It should list the purchase order, shipment, declaration, release, VAT-account transmission, CA3 filing, discovery of the error, notification, correction request and payment. Add the personnel or service providers who handled each step. The chronology can reveal that the French entity was not the importer, that a broker acted without the agreed mandate, that the error arose from a stale EORI, or that the company failed to correct an amount after receiving the import data.

Keep the 2026 legal transition in the chronology. For declarations lodged before 1 September 2026, identify the applicable CGI provisions and the version in force on the relevant date. For declarations after that date, map the CIBS article and any implementing regulation. The relevant CIBS section includes the new rules for the liable person and import declarations; do not cite an article by number without checking the effective-date version. This discipline matters for an international group whose shipment leaves Asia in August, enters a European port in September and is released in France later.

Finally, make the correction proportional to the risk. A one-off typographical error with no tax difference may require a documented administrative correction. A wrong importer, systematic undervaluation, repeated use of another entity’s VAT number, false origin or unsupported customs representation can affect duties, VAT, penalties and criminal exposure. Escalate those facts to counsel and the company’s customs or tax adviser. Preserve the evidence before negotiating a commercial solution with the logistics provider.

For the next shipment, use a release gate with five sign-offs: legal entity and importer; French VAT number; EORI; representation mandate; and customs value and goods classification. The finance reviewer then confirms the CA3 owner and reconciliation method. This short gate is more valuable than a generic group policy because it forces the foreign parent, French company, broker and accountant to identify the same transaction before the goods move.

Conclusion

For a foreign-owned French company, import VAT is a cash-flow opportunity only when the legal entity, customs declaration, French VAT number, EORI, representation mandate and CA3 evidence are aligned. Since 2022, a VAT-identified business can generally declare and deduct import VAT through its French VAT return, but the system depends on accurate pre-arrival data and a genuine right to deduct. The 1 September 2026 recodification adds a new statutory map, not permission to ignore the transaction facts. Before the first shipment, confirm the importer and broker mandate. Before the CA3, match each customs reference, base and VAT amount. After any error, preserve the original declaration, document the correction and identify whether the problem is customs, VAT, accounting or representation. A foreign parent can fund the operation and provide group systems; the French entity must still be able to prove why the amount on its return is correct.

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