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Barreau de Paris Immobilier, sociétés, affaires Fiche CNB avocat.fr
Maître Reda KOHEN, avocat au Barreau de Paris
Maître Reda KOHEN
Avocat au Barreau de Paris

Foreign Company in France and Mandatory E-Invoicing Since 1 September 2026: Receive, Issue, Report and Fix Errors From Abroad

Since 1 September 2026, every company operating in France must be able to receive electronic invoices. If you own a French SAS (simplified joint-stock company), a SARL (limited liability company) or a registered branch (succursale) while living in London, New York, Dubai or Singapore, this reform concerns you directly, even if you never set foot in France. Your French entity has to designate an approved platform (plateforme agréée), receive its supplier invoices in a structured electronic format, and, depending on its size, already issue its own invoices the same way. Paper invoices and simple PDF files attached to an e-mail no longer satisfy the rule for domestic business-to-business transactions. The stakes are concrete: without a compliant invoice, your company can lose its value added tax (VAT) deduction, and the tax administration can apply fines of 50 euros per non-compliant invoice. The good news is that the administration has announced a tolerance period until the end of 2026 for companies facing implementation difficulties, so there is still a short window to get compliant without sanctions. This guide explains, in plain English, what the 1 September 2026 milestone changed, who must issue electronically now and who has until 1 September 2027, how VAT recovery and penalties work, and the practical recovery plan to fix your French company from abroad.

I. What the 1 September 2026 reform requires from your French company

A. Every company must now be able to receive electronic invoices through an approved platform

The headline rule is simple. As the Ministry of the Economy announced on 1 September 2026, generalized business-to-business e-invoicing has entered into force, and every business must now be able to receive an electronic invoice. Every business subject to VAT (assujetti à la TVA) is covered, whatever its turnover, legal form or tax regime. Your one-person SASU (single-shareholder SAS) registered in Paris with a foreign president is covered exactly like a large French group. So is your branch of a foreign company once it is registered in France and identified for VAT.

Receiving means receiving through an approved platform. Invoices must now travel via a plateforme agréée, a private platform approved by the tax administration, using structured formats such as Factur-X, UBL or CII that software can read automatically. A PDF received by ordinary e-mail is no longer an electronic invoice within the meaning of the reform for domestic transactions between taxable businesses. The official guidance states that all businesses receive electronic invoices through an approved platform, and warns companies that have not yet designated a platform to start the process and comply as soon as possible. In practice, you designate your platform directly or through your usual tools: accounting software, management software, your expert-comptable (French chartered accountant), or your bank. The platform registers your company in a national directory (annuaire) so that your suppliers’ platforms can route invoices to you.

This reception duty sits on top of the classic invoicing duty, which has not disappeared. Under the Commercial Code, Article L441-9 of the Code de commerce provides that “Le vendeur est tenu de délivrer la facture dès la réalisation de la livraison ou de la prestation de services au sens du 3 du I de l’article 289 du code général des impôts”, and the buyer must claim it. Under the Tax Code, Article 289 of the Code général des impôts states that “La facture est, en principe, émise dès la réalisation de la livraison ou de la prestation de services.” What the reform changes is the channel: the way invoice data travels becomes regulated, while the substantive rules on VAT, reporting duties and payment deadlines stay unchanged. Your contracts, prices and payment deadlines stay the same; only the pipe through which the invoice travels becomes regulated.

For a foreign owner, three practical points matter immediately. First, your company needs a complete and consistent identity on the platform: SIREN number (the nine-digit company identifier issued at registration), VAT identification number, legal name and address as shown on the Kbis. The Kbis is the official identity card of a French company, an extract issued by the greffe, the clerk’s office of the commercial court, proving the company exists and who can bind it. If the name on the platform differs from the Kbis, invoices get rejected and VAT deductions stall. Second, somebody must actually monitor the incoming flow. Invoices arrive on the platform, not in your personal mailbox. If you live abroad, give your expert-comptable or a clearly mandated employee an access with a defined approval circuit, so that nothing sits unread for weeks. Third, keep the paper reflex for the documents that remain outside e-invoicing: receipts for expenses, foreign supplier invoices and business-to-consumer sales follow different tracks, described below, but they still have to be stored and booked. Under Article L123-22 of the Code de commerce, “Les documents comptables et les pièces justificatives sont conservés pendant dix ans.” Ten years of storage, in euros and in French, remains the baseline whatever the format.

Two official French acronyms you will meet in every discussion deserve a plain explanation. URSSAF is the body that collects social contributions on salaries; it is not involved in e-invoicing, but your accountant will mention it in the same conversation because hiring and payroll data feed the same accounting software. BODACC is the official gazette where company creations, insolvency openings and sales of businesses are published; it also plays no direct role in the reform, but your platform provider may ask for your BODACC notice to verify your registration. Do not let these names distract you: the only directory that matters for the reform is the e-invoicing directory held by the approved platforms.

B. Large and mid-size companies must already issue electronically, while small businesses have until 1 September 2027

The reform works in two waves. Since 1 September 2026, large companies and mid-size companies must issue their invoices in dematerialized format and transmit their e-reporting data. From 1 September 2027, micro-businesses, very small companies and small and medium-sized enterprises must in turn be able to issue electronically and transmit their e-reporting data. In the official summary: at the first milestone, all companies receive and large ones issue; at the second, “les petites et micro-entreprises” must be able to “émettre” electronically and “transmettre leurs données de e-reporting”. More than ten million economic actors are concerned, which is why the tax administration insists that companies start now rather than waiting for the deadline.

Whether your French company issues today or in 2027 depends on its size category. French law distinguishes micro-businesses, small and medium-sized enterprises, mid-size companies (entreprises de taille intermédiaire) and large companies by headcount, turnover and balance-sheet thresholds. A holding company owned from abroad with two employees and modest turnover will normally fall in the second wave and only has to receive for now. A French subsidiary of a foreign group can, however, belong to a larger group whose consolidated figures push it into the issuing wave immediately, so ask your accountant to confirm your category on consolidated figures, not on the French entity alone. If your company must issue, every domestic business-to-business invoice has to leave through your approved platform in a compliant structured format, with the mandatory mentions the platform checks automatically: names and addresses of the parties, SIREN and VAT numbers, date, description, price, VAT rate and amount. If your company is in the second wave, you may still issue electronically voluntarily, and many small companies already do, because it speeds up payment and reduces disputes about lost invoices.

Alongside invoices, the reform created e-reporting, the electronic transmission of transaction and payment data to the tax administration. The official definition describes e-reporting as the electronic transmission of transaction and payment data to the tax administration. All VAT-registered businesses established in France are concerned when they deal with private individuals, certain associations or foreign operators. Concretely, your French company reports its sales to private individuals, its intra-Community supplies, its exports and the purchases it makes from foreign suppliers that it self-assesses. This is the administration’s answer to the blind spots of e-invoicing: transactions with a consumer or a foreign operator never produce a domestic electronic invoice, so the data reaches the tax office through a separate reporting flow sent by your platform on a periodic basis. From the foreign owner’s point of view, the message is that selling online to French consumers from your French company, or buying services from your own foreign parent, does not escape the reform. It simply travels through the e-reporting pipe instead of the e-invoicing pipe.

Two cross-border situations need special attention. First, services supplied to your French company by an operator established outside France. Under Article 283 of the Code général des impôts, “la taxe est acquittée par l’acquéreur, le destinataire ou le preneur qui agit en tant qu’assujetti et qui dispose d’un numéro d’identification à la taxe sur la valeur ajoutée en France” when the supplier is established outside France. This is the reverse-charge mechanism (autoliquidation): your French company declares the French VAT on its own return instead of paying foreign VAT to the supplier, and deducts it on the same return when the conditions are met. Management fees charged by the foreign parent, software licences billed from abroad and intra-group services fall squarely in this box, and the corresponding data feeds e-reporting. Second, sales by your French company to customers outside France. Exports and intra-Community supplies keep their VAT exemption logic, but the transaction data must still be reported electronically. Tell your platform which flows are domestic invoices and which are e-reporting flows; mixing them is one of the most common setup errors in foreign-owned companies whose accountant was never told about the foreign customer base.

A final word on timing and tolerance. The administration has stated that during the start-up phase no sanctions will apply to companies facing difficulties implementing the reform, and that this listening and tolerance phase covers the rest of 2026. This is a welcome breathing space, not an exemption. It covers companies that are genuinely implementing the reform and hit a technical difficulty, not companies that ignore it. Use the last quarter of 2026 to designate your platform, connect your software, clean your customer and supplier master data and run your first compliant flows, so that you enter 2027 with a tested setup. If you run a full setup guide for foreign founders in parallel, our pillar guide on setting up a company in France as a foreign founder, from bank account and Kbis to VAT and first hire covers the registration steps that come before invoicing and remains the reference hub of this series.

II. How a foreign owner secures VAT, evidence and penalties from abroad

A. What a missing, wrong or paper invoice costs: lost VAT deduction and fines

VAT deduction in France starts from the invoice. The Tax Code states the principle in Article 271 of the Code général des impôts: “La taxe sur la valeur ajoutée qui a grevé les éléments du prix d’une opération imposable est déductible de la taxe sur la valeur ajoutée applicable à cette opération.” Only the tax shown on invoices drawn up in accordance with the invoicing rules opens the right to deduct, and the right must be exercised within strict time limits. The Cour de cassation confirmed the discipline in a commercial chamber judgment of 1 October 2025, appeal No. 24-14.456 (ECLI:FR:CCASS:2025:CO00495), holding that the customer of a taxable person who opted for debit-based VAT payment “doit déclarer la TVA déductible figurant sur les factures dans le mois de leur réception et au plus tard le 31 décembre de la deuxième année” following the relevant period. A company that receives invoices and files them without declaring the deductible tax in time can permanently lose the refund, as the liquidator in that case learned at its own expense. For a foreign-owned company whose bookkeeping is done at a distance, the lesson is direct: every incoming invoice must be captured, checked and declared promptly, and the platform is now the place where that capture happens.

A non-compliant invoice therefore hurts twice: it blocks the deduction and it can trigger a fine. The scale sits in Article 1737 of the Code général des impôts. Any omission or inaccuracy in the statutory mentions exposes the issuer to a fine, since “omission ou inexactitude constatée dans les factures ou documents en tenant lieu mentionnés aux articles 289 et 290 quinquies donne lieu à l’application d’une amende de 15 €” per invoice, capped per invoice at one quarter of the invoiced amount. Issuing outside the electronic channel is punished separately: “Le non-respect par l’assujetti de l’obligation d’émission d’une facture sous une forme électronique dans les conditions prévues à l’article 289 bis donne lieu à l’application d’une amende de 50 € par facture, sans que le total des amendes appliquées au titre d’une même année civile puisse être supérieur à 15 000 €.” Refusing the reception side is treated as a persistent breach: the administration first issues a formal notice to comply, since “elle le met en demeure de s’y conformer dans un délai de trois mois”, and fines of 500 euros then 1,000 euros per quarter of continued breach can follow. These amounts apply per invoice or per period and add up quickly for a company issuing hundreds of invoices a month, which is exactly why the platform setup must come before the next billing run, not after the first tax audit.

The same article punishes fictitious invoicing far more severely, with a fine of 50 percent of the amount where a company disguises the identity of its suppliers or customers or issues an invoice with no real underlying supply. Foreign-owned structures must be especially careful here: intra-group invoices between the French subsidiary and the foreign parent have to reflect real services, priced at arm’s length, documented by contracts and time records. A monthly management-fee invoice with a round amount and no description is the classic trigger for a reassessment, and no platform will make an unjustified invoice legitimate. Conversely, a genuine error can be corrected. Tax law treats a corrective document as an invoice in its own right: the Tax Code provides that a document which amends the initial invoice and refers to it specifically and unambiguously is treated as an invoice and must carry the full set of mentions. In practice this means credit notes (avoirs) and corrective invoices issued through the same approved platform, referencing the original invoice number and date, with the corrected mentions. Keep the chain readable: original invoice, credit note cancelling it in whole or in part, then the corrected invoice. An auditor who can follow the chain in three clicks rarely litigates the point; an auditor faced with a deleted invoice and no trace always does.

Storage discipline completes the picture. Tax obligations include keeping a copy of every invoice issued and received, and company law adds the ten-year rule quoted above. Electronic invoices must be stored in their original structured format with their guarantees of authenticity, integrity and readability for the whole retention period, not printed and deleted. Your approved platform usually offers a certified archive, but the legal responsibility stays with your company. When you change accountants or platforms, migrate the archive with the contract and test that old invoices remain readable. A company that can produce, from abroad, any invoice from the last ten years within hours negotiates a tax audit from a position of strength; a company that discovers its archive left with a former provider negotiates from weakness.

B. The recovery plan from abroad: platform, clean data and controlled flows

Put the reform into operation with a short, ordered plan that you can run entirely from abroad with your accountant. First, designate your approved platform now. Consult the official list of approved platforms on the tax administration’s website, choose one compatible with your accounting software, and register your French company with the exact legal identity shown on the Kbis: name, address, SIREN and VAT number. If you use an expert-comptable, ask for a written mandate covering platform administration, invoice validation and e-reporting transmission, with named users and a replacement procedure when your contact leaves the firm. Test the reception flow with a friendly supplier before the first payroll or rent invoice lands: one successful round trip teaches your team more than ten manuals.

Second, clean your master data. Most rejections come from dirty records, not from the software. Verify every French customer and supplier file: SIREN, VAT number checked against the European VIES database, invoicing address versus delivery address, contact person for invoice disputes. For foreign customers and suppliers, record the country, the applicable VAT regime and whether the flow belongs to e-invoicing or e-reporting, so the platform routes it correctly. Update your general terms of sale (conditions générales de vente) and your purchase orders to mention electronic invoicing through an approved platform, and add the platform addresses to your contracts. This single contractual sentence prevents half of the disputes about invoices allegedly never received.

Third, wire the accounting and tax chain end to end. Connect the platform to your accounting software so that validated invoices flow into the books without retyping, and set up the reliable audit trail the Tax Code expects: documented, permanent controls that link each invoice to its underlying supply or service. In the words of the statute, the company must show controls that allow it to establish a reliable link between the invoice and the transaction behind it, which in practice means purchase orders, delivery notes, service reports and bank statements all pointing to the same operation. Configure e-reporting for the flows that need it: sales to private individuals, intra-Community supplies, exports and reverse-charged purchases from abroad. Run the first VAT return (déclaration de TVA) after connection with your accountant line by line, reconciling declared output tax, deductible input tax and reverse-charge entries with the platform reports. A general tax rule worth remembering is that every VAT-registered person must file, keep books enabling the administration to check turnover, and store supporting documents, as Article 286 of the Code général des impôts organises in detail. The platform does not replace the return; it feeds it with cleaner data.

Fourth, repair the past without hiding it. List the invoices issued or received since 1 September 2026 that travelled outside the compliant channel or carry wrong mentions: wrong VAT number, missing SIREN, incorrect rate, absent reference to reverse charge where it applied. Correct them through the platform with credit notes and corrected invoices that reference the originals specifically, and re-file any VAT return that changes as a result. Do not delete or rewrite history: French books must be kept without blanks or alterations, and a visible correction always reads better than a gap. If a supplier refuses to correct its invoice, keep the written exchanges as proof of your diligence; the administration distinguishes a company that chased compliance from one that accepted a defective document silently.

Companies based in Paris and the Paris region face the same national rules, with two local accents. Disputes over VAT assessments and invoice fines go to the administrative courts of your company’s registered office, commonly the administrative court of Paris or its neighbours, and commercial disputes over unpaid invoices go to the commercial court (tribunal de commerce), so keep your contracts’ jurisdiction clauses consistent with your registered address. Practically, Paris accountants, banks and platform providers are fully equipped for the reform and can onboard a foreign-owned company by video call, but make sure the person who signs the platform mandate is the legal representative shown on the Kbis or holds a proper delegation. A platform account opened in the name of the foreign shareholder personally, instead of the French company, is a recurring source of rejected invoices.

Conclusion

Mandatory e-invoicing is now the normal condition of doing business in France, not a pilot project. Since 1 September 2026 your French company must receive through an approved platform; if it is large or mid-size it must also issue and report electronically, and if it is smaller it must be ready to do the same by 1 September 2027. The reform does not change what VAT is due, but it changes how the proof travels, and the proof decides the deduction. A compliant invoice captured on time protects your VAT refund, as the Cour de cassation’s strict case law on declaration deadlines confirms; a defective or off-channel invoice exposes you to fines that scale with volume. The tolerance period running until the end of 2026 gives foreign owners a last calm window to designate a platform, clean their data, connect e-reporting and correct recent invoices through visible credit notes. Companies that use it will enter 2027 with faster payments, fewer disputes and cleaner audits. Companies that wait will discover the reform through a rejected deduction or a fine, which is always the most expensive way to learn a new rule.

Need a quick opinion on your case?

If your French company still has no approved platform, issues paper invoices, or received a notice about e-invoicing, get advice before the tolerance period ends. Our firm offers a telephone consultation within 48 hours with an attorney of the firm. Call +33 6 46 60 58 22 or reach us through our contact page. For official background, see the Ministry of the Economy update on the 1 September 2026 launch, the business guide to e-invoicing and e-reporting and the tax administration portal for switching to e-invoicing.

Source : Cour de cassation – Base Open Data « Judilibre » & « Légifrance ».

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