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Maître Reda KOHEN, avocat au Barreau de Paris
Maître Reda KOHEN
Avocat au Barreau de Paris

VAT Registration in France for a Foreign Company: French VAT Number and Tax Representative

For a foreign founder, obtaining a French VAT number is not a routine consequence of having a French customer, renting a desk in Paris or opening a bank account. It depends on the nature of the transaction, where the transaction is treated as taking place, whether the customer must apply the reverse-charge mechanism, and whether the foreign company has a fixed establishment in France. The same analysis determines whether the business must register, file French VAT returns, appoint a French tax representative, or merely request a refund of French VAT paid on costs.

The practical distinction matters because a French VAT registration does not create a subsidiary, does not turn a foreign company into a French company and does not replace registration with the Guichet unique operated by the French National Institute of Industrial Property (INPI). Conversely, the absence of a French VAT number does not eliminate a French VAT liability when the company makes a taxable sale in France. A founder who invoices first and analyses the position later may face an assessment, late-payment interest, penalties, or a dispute with the customer over the tax-inclusive price.

This article addresses the position of a foreign company doing business in France without treating the individual founder’s residence or immigration status. It explains when a French VAT number is needed, how the European Union (EU) and non-EU rules differ, which documents the French tax authorities request, and how the company should invoice and report. The law cited below is the law checked for this publication on 18 August 2026. A transaction-by-transaction review remains necessary for real estate, events, construction, stock transfers, imports, digital services and other activities with special place-of-supply rules.

I. When must a foreign company register for VAT in France?

A. Do I need a French VAT number if my company is not established in France?

The first question is not “Is my customer French?” but “What operation is being carried out, and where is it located for French VAT purposes?” A company established outside France may sell to French customers without charging French VAT where the applicable rule places the tax in the customer’s country or requires the French business customer to reverse-charge it. The same company may nevertheless need a French identification number for another operation carried out from France, an import, an intra-EU acquisition, a stock movement, a sale to a private customer or a transaction for which the company itself remains liable.

French terminology is important. An assujetti is a person or entity carrying out an independent economic activity within the scope of value-added tax (VAT). The établissement stable is a fixed establishment: a sufficiently permanent French place of business with the human and technical resources needed to receive or make supplies. It is not created merely because the foreign company has a French client, a French lawyer, a French bank account or a temporary meeting room. It can, however, be relevant where personnel, inventory, equipment or decision-making capacity are genuinely organised in France.

Article 286 of the French General Tax Code (Code général des impôts, CGI) imposes an existence declaration on a taxable person. The operative timing is short: the provision says, “Dans les quinze jours du commencement de ses opérations” (within fifteen days of commencing operations). Article 286 CGI also requires activity information and accounting records. For a foreign company without a French establishment, the administrative route is different from the route for a French company, but the timing principle remains a warning: registration should be prepared before the first taxable transaction, not after an invoice has been challenged.

Article 286 ter identifies the situations in which an individual VAT number is assigned. It begins with the rule that “Est identifié par un numéro individuel” every taxable person making supplies of goods or services giving a right to deduction. Article 286 ter CGI then covers intra-EU acquisitions, imports, certain reverse-charge situations and other defined operations. Article 286 ter A provides exceptions, including an entity carrying out only occasional operations or only supplies where the customer is liable for the tax. Its wording includes “ne sont pas tenus de s’identifier par un numéro individuel”. Article 286 ter A CGI must therefore be read together with the actual transaction flow, not treated as a general exemption for every foreign business.

A practical decision tree is useful:

  • If the foreign company has a French fixed establishment carrying out the activity, analyse it broadly as a French operating presence. The establishment may have French reporting, invoicing and record-keeping obligations even though the legal owner remains the foreign parent.
  • If the company sells goods from France, stores its own stock in France, moves goods from France to another EU Member State, imports goods with French VAT consequences, or sells to French consumers in a transaction located in France, French registration is often required.
  • If the company supplies ordinary business-to-business services to a French taxable customer, the French customer may be liable under reverse charge. That result does not automatically require the foreign supplier to obtain a French VAT number for that service, although a separate French operation may change the conclusion.
  • If the company invoices a French private customer, a non-taxable entity, or a business that is not identified for the relevant French VAT treatment, the supplier may remain liable for French VAT. The registration analysis should be completed before the first sale.

The official guidance for foreign companies gives the same practical message. The French tax administration states that, where a foreign company has no fixed establishment in France, registration is necessary when it performs an operation requiring customs identification or the filing of French VAT returns. Its list includes intra-EU acquisitions, supplies from France, certain distance sales, imports, building subcontracting and taxable commercial property leases. The official French VAT registration guidance also confirms that registration may be unnecessary where the foreign company is not liable for French VAT and performs no operation requiring a French number.

The difference between a French tax number and a French company number should be made explicit to the founder. A French SIREN is the nine-digit national identifier of an entity. A SIRET is the fourteen-digit identifier of an establishment: the SIREN plus a five-digit establishment code. A Kbis is the registry extract traditionally used to evidence a company’s registration in the French Trade and Companies Register, the Registre du commerce et des sociétés (RCS). The greffe is the registry office attached to the competent commercial court. None of these labels, by itself, answers the VAT question. A French VAT number normally uses the prefix “FR”, a two-character key and the company’s SIREN; its tax function is separate from the company register.

The distinction is also commercially important. A French customer may ask for a French VAT number even where the invoice should be issued without French VAT under reverse charge. The supplier should not create a number merely to satisfy a procurement form without checking the legal effect. Conversely, a foreign company should not rely on its home-country VAT number when a French registration is legally required. The invoice, the contract, the logistics documents and the VAT return must all tell the same story.

B. Which French VAT rules apply to EU and non-EU businesses?

The second part of the analysis concerns the company’s country of establishment and the person liable for the tax. An EU business with no French fixed establishment may be liable to register and report through the French system when it makes taxable operations located in France. The official French administration identifies the Service des impôts des entreprises étrangères (SIEE), the foreign business tax service within the Direction des impôts des non-résidents (DINR), as the competent service for many such businesses. The address currently published for the SIEE is in Noisy-le-Grand, but the application route and service assignment should be checked against the current official instructions when the file is submitted.

For a normal business-to-business service, the customer’s status matters. Article 283 CGI states that where a service covered by the relevant place-of-supply rule is provided by a supplier not established in France, “la taxe doit être acquittée par le preneur” (the customer must pay the tax). Article 283 CGI is the statutory basis for important reverse-charge cases. The invoice should identify the customer correctly and contain the applicable reverse-charge wording. The foreign supplier should retain evidence that the customer is a taxable business and that the service falls within the relevant rule. A generic “B2B” label is not a substitute for that evidence.

Article 283 also contains specific reverse-charge rules for goods and services supplied by a person established outside France where the French customer has a French VAT identification number. The customer’s number, the nature of the operation and the French place-of-supply rule must all be checked. A customer’s assertion that it will self-account does not relieve the supplier from reviewing whether the statutory conditions are met. If the supplier incorrectly mentions French VAT on an invoice, Article 283 provides a separate risk: a person who mentions VAT on an invoice may become liable because of that invoice, even if the underlying transaction was treated differently.

The rule changes for consumer sales and special operations. Examples include goods delivered in France, certain installation or assembly work, property-related services, admission to events, restaurant and catering services, passenger transport, short-term vehicle hire, construction subcontracting and sales from French stock. Digital and platform businesses also need to examine the special EU schemes and the place of the customer. The company’s contract should be mapped against the specific French and EU rule before the first quotation is sent.

The representative-fiscal question is separate from the VAT-liability question. Under Article 289 A CGI, a person established outside the EU who is liable for French VAT or must complete French VAT reporting is generally required to obtain accreditation for a French taxable representative. The text says that the company “est tenue de faire accréditer auprès du service des impôts un représentant assujetti établi en France”. Article 289 A CGI describes the representative’s role in completing formalities and, in taxable operations, paying VAT on the company’s behalf.

That rule has material exceptions. France maintains a list of non-EU countries with a mutual-assistance instrument of sufficient scope. The current administrative guidance includes the United Kingdom in the published list. An eligible business from the United Kingdom may therefore be able to register without appointing a French tax representative, although it may use a French mandate-holder to make communication easier. The list is not a permanent guarantee: the company should check the version applying on the filing date and retain the source used for the decision.

A non-EU company from a country outside the relevant list should budget for the representative before it starts French operations. The representative must be established and taxable in France, and the accreditation conditions concern organisation, tax history and financial solvency. The representative’s engagement is not a simple postal address. It can involve the preparation of returns, payment, refund claims, records and exposure to tax liabilities. The agreement should define the operations covered, the effective date, access to invoices and customs records, deadlines for transmitting information, and who funds a tax assessment caused by missing documents.

Article 289 A bis creates a narrower mandate route for a person neither established nor identified in France where the only French operations are defined import or third-country operations. The provision requires an eligible French intermediary, a written mandate and specific control conditions. Article 289 A bis CGI is not a general alternative to the tax representative requirement. It should be used only after the operations have been compared with its wording.

There is a further trap for a foreign founder who has both a parent company and a French subsidiary. The subsidiary has its own legal personality and its own French tax identity. The foreign parent’s invoices and the subsidiary’s invoices are not interchangeable. Management services, licences, stock transfers, cost recharges and intercompany loans may each have different VAT consequences. A parent’s VAT number cannot simply be printed on a French subsidiary’s invoice, and a subsidiary’s registration cannot automatically cure a parent’s failure to register for a taxable French operation.

II. How do I obtain a French VAT number and stay compliant?

A. What documents and deadlines are required for French VAT registration?

The route depends on the operating model. A newly formed French company normally passes through the INPI-operated single filing portal, receives its French identifiers after the registration process and is then handled by the competent French tax office for its VAT regime. A foreign company without a French fixed establishment uses the procedure indicated by the tax administration for foreign businesses, generally through the French business formalities portal, and is connected to the SIEE or another competent service according to its circumstances. The exact online screens can change; the legal analysis and supporting documents should be ready before the filing begins.

The official foreign-business VAT page lists the core documents. The applicant should expect to provide a recent certificate of registration in the home-country commercial register or equivalent, the foreign company’s constitutional documents, and a translation into French of the principal information such as legal form, shareholders, directors and share capital. For documents written in a language outside the EU framework, the administration may require a sworn translation. An individual business may have to provide identification documents. A mandate is needed where a French representative or optional agent acts for the company. The impots.gouv.fr document checklist should be saved with the submitted file because it explains the form and the current service route.

The file should also contain information that prevents avoidable questions:

  • a precise description of the goods or services supplied in France;
  • the expected first taxable transaction and the proposed start date;
  • the countries of customers and suppliers;
  • the location of stock, equipment, employees and subcontractors;
  • sample contracts, purchase orders or invoices showing the intended VAT treatment;
  • customs information, including the Economic Operators Registration and Identification (EORI) position where goods cross a customs border;
  • the foreign VAT number and company registration details;
  • bank information for future payments or refunds; and
  • the name and email address of the person authorised to correspond with the SIEE.

A bank account is not normally a substitute for the legal file, but the administration states that a French or SEPA-compatible account can facilitate later VAT-credit refunds. A business established outside the SEPA area should anticipate the evidence required for an account held abroad. The account-holder name should match the company or the properly authorised representative. This small consistency check can save weeks when the company later requests repayment of input VAT.

The VAT number itself is not a licence to invoice every French customer with French VAT. It is an identification tool attached to the company’s liability and reporting obligations. Once the number is issued, the company should check that the details displayed by the European Commission’s VAT Information Exchange System (VIES) are consistent with the commercial name and country. The French public service explains that the French number combines “FR”, a two-character key and the nine-digit SIREN. The official Service Public page on intra-EU VAT numbers also explains that the number should appear on relevant commercial and administrative documents and provides the official validation route.

Timing must be handled in two layers. First, the company should submit the existence and identification information within the statutory period linked to the start of operations. Article 286 uses the fifteen-day wording quoted above. Second, the company must allow administrative processing time for a foreign file, translation review, representative accreditation and requests for clarification. There is no safe universal promise that a number will be issued within a particular number of business days. The company should not issue a taxable invoice on the assumption that a pending application suspends the tax liability. If commercial pressure requires a quotation before the number is issued, the quotation should state that the final VAT treatment remains subject to the transaction analysis and the customer’s status.

Founders should prepare a one-page VAT matrix before filing. The columns should identify the transaction, customer type, customer VAT number, goods or services, dispatch and delivery location, supplier establishment, applicable place-of-supply rule, person liable for VAT, invoice wording, return line and supporting evidence. The matrix is particularly useful where the company sells both business-to-business services and consumer products. It also lets the tax representative or accountant identify the transactions that require a French number even though the headline business model is cross-border consulting.

When the company has a French subsidiary or branch, the registration file should not confuse the foreign parent’s documents with the French entity’s documents. A branch, or succursale, is not a separate legal person from the foreign company. A subsidiary is a separate company. A bureau de liaison, or liaison office, may conduct only non-commercial promotional activity and is not a safe structure for invoicing French customers. The commercial register extract, the INPI filing, the Kbis or registry evidence, the tax registration and the VAT number must be checked against the structure that actually signs the contract.

B. How should a foreign company invoice and file French VAT returns?

Invoicing begins with classification, not software. Article 289 CGI requires an invoice in the situations covered by the provision, and the text states that “Tout assujetti est tenu de s’assurer qu’une facture est émise”. Article 289 CGI also requires the retention of duplicate invoices and addresses the currency and translation of invoices. A foreign company may invoice in pounds, dollars or another currency, but the VAT amount to be paid or regularised must be determined in euros under the applicable conversion rule.

A compliant invoice should normally show the supplier’s legal name and address, the customer’s details, invoice date and number, the date of supply or payment where required, a clear description, quantity and price, the taxable amount, the rate and amount of VAT or the legal basis for not charging it, and the relevant VAT identification numbers. When reverse charge applies, the invoice should use the required “reverse charge” wording and should not add French VAT merely because the customer is located in France. When an exemption or export treatment is claimed, the legal reference and the evidence of dispatch or export should be retained.

Article 289-0 extends French invoicing rules to operations treated as located in France, subject to exclusions where the foreign supplier’s customer is liable for the tax. For a foreign supplier, the contract, the invoice and the VAT return should be reviewed as one file. If the invoice says “French VAT 20%”, the return should account for collected tax. If it says “reverse charge”, the file should demonstrate why the customer is liable. If it says “export”, customs and transport evidence should be available. A mismatch is an audit signal even where the amount of tax is ultimately recoverable.

The reporting obligation is set out in Article 287 CGI. It requires a taxable person identified under Articles 286 ter and 286 ter A to submit a declaration within the time set by the administration. Under the normal regime, the return is filed monthly and the tax due is paid monthly; where the annual tax due is below €4,000, quarterly filing may be permitted. Article 287 CGI should be read with the current instructions shown in the professional tax account. A simplified regime has separate advance-payment rules, including July and December instalments, but a non-established foreign company should not assume that the simplified regime applies without an explicit tax classification.

The French administration distinguishes the CA3 return, the standard return for the normal VAT regime, from other declarations such as the European declaration of services (DES) and the statement of intra-EU goods flows. The former concerns French VAT due and deductible; the latter may concern cross-border reporting even where no French VAT is charged. Goods businesses should also examine import declarations, the EORI number and proof of transport. Service businesses should document the customer’s taxable status and the place where the service is used or supplied under the relevant rule.

Small businesses must be particularly careful with the French franchise en base de TVA, a domestic VAT-franchise regime. Article 293 B says that qualifying businesses established in France can benefit from a franchise that dispenses them from paying VAT within the statutory turnover limits. Article 293 B CGI is not a universal safe harbour for a foreign company with French transactions. The foreign company’s establishment, the country of establishment, the type of operation and the special EU scheme must be considered before the company writes “VAT not applicable” on an invoice.

From September 2026, the electronic-invoicing and electronic-reporting timetable creates an additional implementation issue. Article 289 bis CGI requires electronic invoicing through an approved platform for defined transactions between taxable persons established or resident in France. Article 289 bis CGI should not be confused with e-reporting by a foreign company that is not established in France. Article 289 E provides that electronic-invoice data is transmitted to the administration through the approved platform chosen by the taxable person. Article 289 E CGI is a recent legislative reference that should be included in the compliance timetable.

The public timetable currently published for foreign companies without a French fixed establishment states that e-reporting applies from 1 September 2026 to large companies and intermediate-sized enterprises that are sellers or service providers, and from 1 September 2027 to micro-enterprises, very small enterprises and small or medium-sized enterprises in that role. The classification is assessed in the manner described by the administration and can concern the company’s international activity, not only its French turnover. The company should confirm its category, select a compliant platform or reporting route, test data fields, and decide who will transmit the customer, supplier, VAT and transaction information. The official e-reporting timetable for foreign companies should be checked again before the relevant start date.

Records are the practical defence in a VAT audit. Keep the contract, order, customer VAT validation, invoice, delivery or transport proof, customs documents, bank receipt, return calculation and correspondence that explains the classification. Article 286 requires records and supporting documents. Article L. 176 of the Book of Tax Procedures provides that, for turnover taxes, the administration’s reassessment power normally runs until the end of the third year following the year in which the tax became chargeable. Article L. 176 LPF also contains a ten-year exception for specified cases such as concealed activity or a tax-fraud report. The retention policy should therefore be longer than the period needed to prepare the monthly return.

French case law illustrates why documentary shortcuts are dangerous. In its decision of 20 December 2018, second civil chamber, appeal no. 15-26.723, the Cour de cassation dealt with intra-EU stock transfers and the interaction between fiscal declarations and business turnover. The official decision records that “les transferts intracommunautaires considérés doivent être déclarés dans l’imprimé 3310 CA3”. Cour de cassation, 20 December 2018, no. 15-26.723. The case was not a general registration checklist, but it is a useful reminder that an exempt or non-taxable line can still have reporting consequences.

In its criminal chamber decision of 20 April 2017, appeal no. 15-86.742, the Cour de cassation examined a fraudulent VAT treatment of imported vehicles. The decision states that the customs clearance document, or quitus, “n’a qu’une valeur déclarative”. Cour de cassation, 20 April 2017, no. 15-86.742. The point for a foreign company is immediate: a tax or customs document does not validate a VAT treatment that the underlying transaction does not support. The company must preserve the commercial and logistical evidence behind the tax position.

A VAT-credit refund also deserves advance planning. A foreign company that is not liable for French VAT on its sales may still incur French VAT on professional costs. Depending on its establishment and the applicable refund procedure, it may claim through the electronic portal of its EU country, through the French process, or through an accredited French representative. Refund eligibility is not identical to registration eligibility. A company that wants a refund should keep invoices in the legal entity’s name, demonstrate business use, provide bank details and verify whether the expenses are deductible under French rules.

The final pre-launch checklist is straightforward:

  1. Map every French transaction and identify the person legally liable for VAT.
  2. Check whether there is a French fixed establishment, French stock, a branch, a subsidiary or only cross-border supplies.
  3. Apply the EU/non-EU and tax-representative analysis under Article 289 A, including the current mutual-assistance list.
  4. Prepare the registration file, translations, mandate, bank evidence and sample contracts before the first taxable operation.
  5. Obtain and validate the French VAT number; do not confuse it with the SIREN, SIRET, Kbis or EORI number.
  6. Configure invoices, reverse-charge wording, customer VAT checks, customs evidence and the CA3 return.
  7. Build a monthly compliance calendar for declarations, payments, DES or goods reporting, refunds and e-reporting.
  8. Keep an evidence file that permits a third party to reconstruct why VAT was charged, reverse-charged, exempted or reclaimed.

Conclusion

A foreign company does not need a French VAT number simply because it wants to sell into France. It needs one when French law assigns it an identification or reporting obligation, and the answer turns on the transaction, the customer, the place of supply, the company’s French presence and the person liable for the tax. For an EU business, the central issues are the taxable operation and the reverse-charge evidence. For a non-EU business, the representative-fiscal question can determine whether the business may start invoicing at all. For every business, the safest sequence is to classify the operation, assemble the documents, register before the first taxable transaction, and make the invoice, return and evidence file consistent.

Need a quick view on your case?

Arrange a telephone consultation within 48 hours with a lawyer from the firm.

We can review your proposed structure, VAT registration route, representative-fiscal exposure and first invoices. Call +33 6 46 60 58 22 or use the contact page for Maître Reda Kohen.

For a wider overview of the first legal steps, see our guide to setting up a business in France as a foreign founder.

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

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