You run a consultancy in London, a software studio in New York, an engineering firm in Warsaw or a design agency in Casablanca, and a French business client asks for your invoice. Your first instinct may be to add 20 percent French VAT, or to panic about registering for VAT in France before you can be paid. In most business-to-business cases, both reflexes are wrong. When you supply services from abroad to a French client that is itself a VAT taxpayer, French VAT is generally due not by you but by your client, through the reverse-charge mechanism known in French as autoliquidation: you invoice without VAT, your client declares the tax and deducts it on the same return, and no French VAT registration is needed on your side. But the mechanism has sharp edges. Invoice French VAT when you should not and you owe it by the mere fact of writing it. Forget the compulsory wording and your client cannot process the invoice. Work on a French building site as a subcontractor, supply a customer with no French VAT number, or route the billing through an intermediary, and the VAT falls back on you, with registration, a fiscal representative for non-EU suppliers, and penalties. This article explains in order when the French client self-accounts for the tax, which transactions escape the mechanism, how to invoice and declare correctly from abroad, and what happens when the circuit breaks, including a criminal case where a cross-border invoicing scheme ended in a fraud conviction. Every acronym is explained and every decisive statement is tied to the statute, to the official tax administration guidance or to a published court decision.
I. When your French business client owes the VAT instead of you
The starting point is where the service is legally located. For business-to-business supplies, European rules place the service where the customer is established, and French law reproduces that principle in article 259 of the General Tax Code (CGI, Code général des impôts, the French tax statute): “Le lieu des prestations de services est situé en France : 1° Lorsque le preneur est un assujetti agissant en tant que tel et qu’il a en France : a) Le siège de son activité économique”, with the same logic for a French permanent establishment (établissement stable, a fixed place of business such as an office or branch through which the company operates) or, failing that, a French domicile or habitual residence, as article 259 provides. An assujetti is a taxable person, meaning any business carrying on an economic activity independently, whether or not it actually pays VAT. So when your French client, acting as a business, buys your consulting, software, design or engineering services, the service is located in France and French VAT applies in principle. The decisive question is who pays it, and that is where the reverse charge enters: “Lorsque les prestations mentionnées au 1° de l’ article 259 sont fournies par un assujetti qui n’est pas établi en France, la taxe doit être acquittée par le preneur”, states article 283-2 of the CGI. You are not established in France, your French business client receives the service in France, therefore your client pays the tax, not you. The European foundation is article 196 of the VAT Directive (directive 2006/112/CE, the EU-wide VAT framework): the customer is liable where services are supplied by a taxable person not established in the Member State where the tax is due (Council Directive 2006/112/EC, Article 196). The French tax administration (DGFIP, Direction générale des finances publiques, the French tax authority) confirms the practice in plain terms on its official guidance page for business-to-business services: the person liable for the tax (redevable) is the customer receiving the service (impots.gouv.fr, Prestations entre assujettis). The redevable is the person legally liable for the tax. In the standard case, that person is your French customer.
For your client, the mechanism is designed to be financially neutral but administratively strict. The client declares the VAT on its French VAT return (déclaration CA3, the standard French VAT return form no. 3310-CA3-SD, filed monthly or quarterly) and deducts the same amount as input VAT on the same return, so no cash changes hands, but both lines must appear. The administration’s guidance gives the exact lines: for purchases from a supplier established in another EU Member State, the taxable base goes on line A3 for purchases of services from a supplier not established in France under article 283-2 of the CGI, and for a supplier outside the EU on line A2 for “Autres opérations imposables”, with the tax itself on the rate lines and the deductible amount on line 20 for “autres biens et services” (impots.gouv.fr, Prestations entre assujettis). If you have formed a French company that now buys services from your foreign parent or sister company, the same logic applies in reverse, and our guide on choosing between an SAS, an SARL, a branch and a subsidiary from abroad helps you decide whether the French buyer should be a subsidiary, which files its own CA3, or a branch, whose filings run through the foreign head office. One practical condition underlies everything in this section: your client must hold a valid French VAT identification number (numéro de TVA intracommunautaire, the individual VAT number issued to each EU business, verifiable on the European Commission’s VIES database). Check it before invoicing and keep the verification printout, because several of the exceptions below turn precisely on whether that number exists. Note also that the CGI articles cited in this article are shown by Légifrance as recodified with effect in 2027; they are fully applicable to transactions at the date of this article, and the substance of the reverse charge is unchanged.
A. Business services supplied from abroad to a French taxable customer: the general reverse charge
The general case covers the daily work of foreign founders selling into France: strategy consulting delivered from London, software development from Warsaw, marketing services from New York, architectural studies from Casablanca for a project outside France, intra-group management fees charged to the Lyon subsidiary. In each case, three conditions together trigger the reverse charge: the supplier is not established in France, the customer is a taxable person acting as such, and the service falls under the general place-of-supply rule of article 259-1 rather than one of the listed exceptions. When those three conditions are met, the supplier must not charge French VAT, must not register for French VAT for that supply, and must let the customer self-account. The administration’s page for non-EU businesses states the principle from the supplier’s side: for certain transactions, VAT is no longer paid by the business established outside France but directly by the buyer or customer holding a French VAT number, a mechanism called autoliquidation (impots.gouv.fr, TVA Entreprise hors UE). The wording matters: the mechanism applies when the customer holds a French VAT number. A French client that is a private individual, a small business under the VAT exemption threshold (franchise en base, the French small-business exemption that releases small turnovers from charging VAT) with no intra-EU VAT number, or a foreign company with no French VAT number, cannot self-account, and the analysis shifts to Section B. For goods, the parallel logic runs through intra-EU supplies and acquisitions, distance sales and the import rules, which follow their own thresholds and registration duties and are outside this article; what matters here is that for cross-border B2B services, the default answer to whether French VAT must be charged is no, and a French VAT number is generally not needed to send the invoice either.
The neutrality of the mechanism for the client does not make it optional. Your French customer must actually enter the transaction on its CA3, on the correct lines recalled above, and a customer that forgets faces reassessment of the VAT plus late-payment interest and penalties, even though deduction would have cancelled the cash effect. That is why serious French buyers ask foreign suppliers for clean paperwork: a valid VAT number of their own, your business details, and an invoice that lets their accountant book lines A2 or A3 without hesitation. Anticipate the request in your sales process rather than discovering it when the client’s accounts department blocks your invoice. If the relationship is continuous, align on the format once: invoice currency, description of the service precise enough to show it falls under the general rule, your foreign VAT or tax number, the client’s French VAT number, and the compulsory reverse-charge wording examined in Part II. Done properly, the reverse charge is invisible in your pricing and painless in the client’s return; done approximately, it generates blocked invoices, renegotiations and, in the worst cases, the disputes described in Part II.
B. The transactions that escape the mechanism: French property, construction subcontracting and customers without a French VAT number
Three families of transactions pull the VAT back onto the supplier or change the circuit, and each corresponds to a frequent foreign-founder situation. The first is services connected with French real estate. Article 259 A of the CGI derogates from the general rule: “Par dérogation à l’article 259 , est situé en France le lieu des prestations de services suivantes”, including “2° Les prestations de services se rattachant à un bien immeuble situé en France, y compris les prestations d’experts et d’agents immobiliers”, hotel-type accommodation, rights of use over buildings, and architectural and supervision services for construction works, as article 259 A lists. If you advise, broker, design or supervise works on a building located in France, the service is French-located by nature, not by customer. The reverse charge still helps where it can: article 283-1 provides that “lorsqu’une livraison de biens ou une prestation de services mentionnée à l’ article 259 A est effectuée par un assujetti établi hors de France, 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” (CGI, article 283-1). So a French developer client with a French VAT number still self-accounts even for property-related services. But a private buyer, a non-taxable person or a client with no French VAT number cannot, and then you, the foreign supplier, owe the French VAT, which means registering and declaring in France.
The second family is construction subcontracting, the classic trap for foreign building firms working on French sites. Article 283-2 nonies of the CGI provides: “Pour les travaux de construction, y compris ceux de réparation, de nettoyage, d’entretien, de transformation et de démolition effectués en relation avec un bien immobilier par une entreprise sous-traitante, au sens de l’ article 1er de la loi n° 75-1334 du 31 décembre 1975 relative à la sous-traitance, pour le compte d’un preneur assujetti, la taxe est acquittée par le preneur” (CGI, article 283-2 nonies). A Portuguese electrician, a Polish formwork company or a Romanian painting firm working as a subcontractor on a French building site therefore invoices without VAT and the French main contractor self-accounts, even though the work is physically performed in France. Note the boundary: the provision covers subcontractors working for a taxable principal, not the main contractor billing the end client, and it sits alongside the labour-law posting obligations (SIPSI declaration, French pay rules, A1 certificates) that apply to the workers on that same site. VAT compliance and posting compliance run in parallel and neither replaces the other.
The third family is the customer with no French VAT number, including most non-taxable persons and small exempt businesses. Where the customer cannot self-account, the foreign supplier becomes the person liable and must fulfil French VAT obligations: registration, returns, payment. For suppliers established outside the European Union, article 289 A of the CGI adds a representative requirement: “Lorsqu’une personne non établie dans l’Union européenne est redevable de la taxe sur la valeur ajoutée ou doit accomplir des obligations déclaratives, elle est tenue de faire accréditer auprès du service des impôts un représentant assujetti établi en France qui s’engage à remplir les formalités incombant à cette personne et, en cas d’opérations imposables, à acquitter la taxe à sa place” (CGI, article 289 A). The représentant fiscal, a VAT-registered person established in France accredited with the tax office, files and pays in your place. The administration confirms: a business established outside the EU with no French permanent establishment that carries on VAT-taxable activity must appoint a fiscal representative established in France to complete the formalities in its place (impots.gouv.fr, TVA Entreprise hors UE). Limited exemptions exist, notably where France has a mutual-assistance instrument with the supplier’s country or for supplies where the customer self-accounts anyway. And the statute adds a sting in the tail: “A défaut, la taxe sur la valeur ajoutée et, le cas échéant, les pénalités qui s’y rapportent, sont dues par le destinataire de l’opération imposable” (CGI, article 289 A). Without a representative, your French customer can be asked to pay your VAT and the related penalties. No serious buyer accepts that risk without a discount or a guarantee, which is why the representative question belongs in the contract negotiation, not in a panic after the first invoice.
II. How to invoice and declare correctly from abroad, and what mistakes cost
Once the analysis points to reverse charge, execution is a matter of exact paperwork. French VAT runs on invoices: the law requires every taxable person to ensure an invoice is issued for supplies to another taxable person, as article 289 of the CGI states: “Tout assujetti est tenu de s’assurer qu’une facture est émise, par lui-même, ou en son nom et pour son compte, par son client ou par un tiers” for the listed transactions (CGI, article 289). The foreign supplier therefore issues a real invoice, but a specific one: without VAT, with both VAT numbers, and with the reverse-charge wording. From 2026 the French electronic-invoicing reform adds a transmission layer to this paper, with structured invoices exchanged through certified platforms; the VAT analysis in this article does not change, but the invoice must additionally satisfy the electronic format, on which our guide to French e-invoicing for foreign companies gives the practical steps.
A. Issue the invoice without VAT, state the reverse charge and verify your client’s number
The golden rule of reverse-charge invoicing is negative: do not write VAT on the invoice. Article 283-3 of the CGI provides: “Toute personne qui mentionne la taxe sur la valeur ajoutée sur une facture est redevable de la taxe du seul fait de sa facturation” (CGI, article 283-3). A London consultant who adds 20 percent “French TVA” to help the Paris client, or a US software company whose template automatically prints a VAT line, becomes liable for that tax by the mere fact of printing it, even if no registration existed and no VAT was legally due. The correction is to invoice excluding tax (hors taxe, HT, the price before VAT) and to carry the wording that tells the client’s accountant which mechanism applies. The administration’s guidance gives the reference formulas from the mirror situation, which apply symmetrically: the French supplier issues an invoice without VAT, bearing the word autoliquidation for an EU-established taxable customer and a reference to article 259-1 of the CGI for a customer established outside the EU (impots.gouv.fr, Prestations entre assujettis). As a foreign supplier to a French taxable client, your invoice therefore shows the HT price, both parties’ VAT numbers, and the “autoliquidation” mention with the legal basis, typically a reference to article 283-2 of the CGI and article 196 of the VAT Directive. Keep the invoice, the contract describing the service, the proof of the client’s French VAT number with its VIES verification date, and the evidence that the service falls under the general rule rather than the property exception. This file is what you produce if the administration questions why no French VAT was charged, and it is also what your client’s auditor will request at year-end.
Verification of the client’s number deserves a procedure of its own, because the whole circuit depends on it. Check the French VAT number on the VIES database before the first invoice and re-check periodically for ongoing relationships, since numbers can be invalidated. If the number is invalid or the client refuses to provide one, stop the reverse-charge route: either the client is not a taxable person for this purchase and the place-of-supply analysis changes, or you face the registration and representative duties of Section I.B. Never invent a number and never reuse an old one without re-checking. For the client’s declaration, remind a new or small French customer of the CA3 lines recalled in Part I, because a client error does not legally fall on you but commercially comes back to you as a disputed invoice. Finally, mind the currency and rate details: the taxable base is converted where needed, the rate applied by the client is the French rate for the service (usually 20 percent, the standard French VAT rate, with reduced rates only where the statute grants them), and the deduction is entered on the same return, preserving the neutrality the mechanism promises. None of this requires your registration; all of it requires your precision.
B. When the circuit breaks: reassessment, joint liability and the criminal line
Errors in this area are rarely neutral because the administration reads them as missing tax. The first sanction is civil and automatic in logic: where VAT should have been charged or self-accounted and was not, the administration reassesses the liable person, adds late-payment interest and applies penalties proportionate to the behaviour, from simple omission to deliberate failure. False invoices are treated more severely by the statute itself: “Lorsque la facture ne correspond pas à la livraison d’une marchandise ou à l’exécution d’une prestation de services, ou fait état d’un prix qui ne doit pas être acquitté effectivement par l’acheteur, la taxe est due par la personne qui l’a facturée” (CGI, article 283-4). And the customer is not a safe spectator: article 283-4 bis makes a customer who knew or could not have been unaware that the VAT would fraudulently not be paid jointly liable for it with the supplier. A French client that accepts suspiciously undocumented invoices from a foreign supplier at an abnormal discount, without checking the VAT number or the reverse-charge wording, therefore risks paying the missing VAT itself.
The criminal line is crossed where declarations are deliberately understated or omitted within an organised scheme. The Cour de cassation upheld such a conviction on 30 May 2001 (case no. 00-86.897) in a configuration close to modern cross-border practice: a French company invoiced assistance services on behalf of its English parent, the French customer deducted the VAT shown on the invoices, but neither the French intermediary nor the foreign parent declared the corresponding receipts or paid the tax to the Treasury. The Court of Appeal found “l’existence d’un montage élaboré permettant, par le biais de conventions financières passées entre trois sociétés, d’éluder le paiement de la taxe”, and the Cour de cassation confirmed that these findings revealed “sous l’apparence d’opérations régulières, l’existence d’une fraude caractérisée”, rejecting the appeal (Cass. crim., 30 May 2001, no. 00-86.897, rejection). The manager had been sentenced to eighteen months’ imprisonment suspended and a 100,000-francs fine for filing understated VAT returns. The age of the decision does not weaken its lesson, because the mechanism it punishes is timeless: deductible VAT on the customer’s side with no corresponding declaration on the supplier’s side is exactly what inspectors look for, and cross-border chains with an intermediary make the pattern more visible, not less. Keep every link of your chain declared: your invoice without VAT, the client’s A2 or A3 line, and, where you are yourself the liable person, your registration, representative and returns.
If a reassessment arrives, the standard French tax procedure applies: administrative claim (réclamation) to the tax office within the legal time limit, then appeal to the administrative court (tribunal administratif) if the reply is negative or late. From abroad, three reflexes protect the file: answer through your fiscal representative or appointed counsel so no deadline is missed, since time limits run regardless of distance; produce the complete circuit file described in Section A, because a documented reverse charge with a verified client number is the strongest defence; and correct remediable points immediately, such as adding missing invoice mentions or regularising a registration, since good faith and prompt correction weigh in the calibration of penalties. Where the dispute concerns the place of supply itself, for example whether architectural supervision for a French site falls under the property exception, assemble the contract, the site evidence and the correspondence showing the nature of the service before arguing, because qualification disputes are won on documents, not on assertions. And if you discover the error yourself before any control, spontaneous regularisation almost always costs less than a reassessment: file, declare and pay with the applicable interest rather than waiting for the inspector’s letter.
Conclusion
Selling services into France from abroad rarely requires charging French VAT or registering for it: where your customer is a French taxable person with a French VAT number and the service falls under the general rule, your client self-accounts through the reverse charge while you invoice excluding tax with the “autoliquidation” wording and keep the verification file. The exceptions define the rest of the work: French property-related services, construction subcontracting with its dedicated reverse charge onto the principal, and customers without a French VAT number, where registration and, outside the EU, a fiscal representative become compulsory. Writing VAT on an invoice when none is due creates the liability by itself, false circuits trigger joint liability, and organised under-declaration ends, as the courts have shown, in criminal fraud. Structure each cross-border invoice as a small compliance file before sending it, and the French VAT circuit stays what it should be: invisible in your price and indisputable in your client’s return.