You run your business from London, New York, Geneva or Singapore. You have no French company, no French office and no French employee, yet France keeps asking you for a French VAT number. A French customer refuses to pay your invoice because it shows no French VAT number. A logistics provider warns that your stock in a warehouse near Lyon cannot move without one. Your accountant mentions a fiscal representative in Paris and a registration with a tax office you have never heard of, the SIEE, and quotes a fee that makes you wonder whether the French market is worth the trouble. This article answers the four questions every foreign business asks in this order: do I really need a French VAT number when I have no French company, who issues it and through whom, how do I register and invoice correctly from abroad, and how do I fix the situation if I traded in France without one. The answers rest on the French Tax Code as in force on 14 September 2026, on the official guidance of the French tax administration, the customs administration and the public service portal, and on a published February 2026 ruling of the Cour de cassation, the court at the top of the French judicial system, in a case opposing FedEx to the customs authorities over almost two million euros of VAT on imports shipped by an American company. It complements our general guide for foreign founders on setting up a company in France, from bank account and Kbis to VAT and first hire, and our companion pieces on missed French VAT returns, on billing French clients without a French VAT number and on French electronic invoicing from September 2026. Fix the acronyms now and the rest follows. VAT is the English name of the TVA, the taxe sur la valeur ajoutée. The SIE, service des impôts des entreprises, is the local corporate tax office that handles domestic companies. The SIEE, service des impôts des entreprises étrangères, is the dedicated office for foreign businesses without a French establishment, attached to the DINR, the direction des impôts des non-résidents, the tax directorate for non-residents. The Kbis is the identity card of a French company, issued by the greffe, the registry of the local commercial court. VIES is the European database where any business can check the validity of a VAT number. None of these offices requires you to create a French company first, and that single point unlocks the whole procedure.

I. Do You Really Need a French VAT Number When You Have No French Company?

A. When French law forces a foreign business to register for French VAT

The starting rule is deliberately broad. Article 256 of the French Tax Code provides: « Sont soumises à la taxe sur la valeur ajoutée les livraisons de biens et les prestations de services effectuées à titre onéreux par un assujetti agissant en tant que tel. » In plain terms, any supply of goods or services for consideration by a taxable person falls within VAT, and nothing in that sentence mentions nationality, residence or the possession of a French company. What matters is not where you live but where the transaction is legally located, and French law answers that question with two separate place-of-supply rules, one for goods and one for services. For goods, Article 258 of the French Tax Code states: « Le lieu de livraison de biens meubles corporels est réputé se situer en France lorsque le bien se trouve en France : a) Au moment de l’expédition ou du transport par le vendeur, par l’acquéreur, ou pour leur compte, à destination de l’acquéreur » If the goods are in France when they start moving toward your customer, the sale is a French sale for VAT purposes even if you signed the contract in London or New York. Storing stock in a French warehouse and selling from that stock is the textbook case: every domestic sale from the warehouse is located in France, and registration becomes unavoidable. For services, Article 259 of the French Tax Code provides: « 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 » Read with the following paragraphs of the same article, the logic is that services supplied to a French taxable customer are generally located where that customer sits, while services to private individuals follow different connectors that often point to the supplier. The practical consequence is asymmetrical and counter-intuitive, so test your own flows against it. A consultancy invoice from a London firm to a Paris company that holds a French VAT number is normally located in France but does not force the London firm to register, because the reverse-charge mechanism described below shifts the VAT to the French customer. The same service billed to a French private individual, by contrast, can make the foreign supplier directly liable for French VAT and therefore push it into registration. Imports follow their own rule. Article 291 of the French Tax Code states: « Les importations de biens sont soumises à la taxe sur la valeur ajoutée. » and adds: « Est considérée comme importation d’un bien : a. l’entrée en France d’un bien, originaire ou en provenance d’un Etat ou d’un territoire n’appartenant pas à l’Union européenne, et qui n’a pas été mis en libre pratique » Bringing goods from outside the European Union into France is a taxable import, and someone must be designated to pay that VAT at the border, which is exactly where the representation questions examined below begin. Exports point the other way. Article 262 of the French Tax Code provides: « Sont exonérées de la taxe sur la valeur ajoutée : 1° les livraisons de biens expédiés ou transportés par le vendeur ou pour son compte, en dehors de la Communauté européenne ainsi que les prestations de services directement liées à l’exportation » Goods that genuinely leave the European Union are exempt, which is why the file must prove the exit with transport and customs documents rather than with commercial assertions. Between these poles sits the mechanism that spares many foreign businesses a registration: the reverse charge. Article 283 of the French Tax Code states that where such a supply is made by an operator established outside 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 » When your French customer is itself identified for French VAT, the customer accounts for the tax and you invoice without French VAT, usually with the mention autoliquidation and both VAT numbers on the invoice. Three conditions must coincide for this shelter to hold: the supply must fall within the listed categories, you must be established outside France, and the customer must hold a valid French VAT identification number that you have actually checked on VIES before invoicing. If any leg fails, the shelter collapses and registration returns to the table. Once registration is due, the declaration duty is immediate and personal. Article 286 of the French Tax Code requires: « Dans les quinze jours du commencement de ses opérations, souscrire au bureau désigné par un arrêté une déclaration conforme au modèle fourni par l’administration. » Fifteen days from the start of taxable operations, not from the end of the quarter and not from the accountant’s next visit. The import mirror of that duty appears in Article 1695 of the French Tax Code, which states: « La taxe sur la valeur ajoutée est déclarée et perçue lorsqu’elle devient exigible, pour les opérations suivantes : 1° Les importations pour lesquelles le redevable est une personne non assujettie et non identifiée conformément aux dispositions combinées des articles 286 ter et 286 ter A » A non-identified importer pays at the border without deferral, while an identified operator can move the import VAT onto its domestic return. That single difference often pays for the whole registration effort within months for businesses that import regularly. None of this requires a French subsidiary, a branch or a Kbis. French VAT identification and French company registration are two separate tracks: the company track runs through the company formalities desk to the greffe and produces a Kbis, while the VAT track for a business without a French establishment runs to the SIEE and produces a French VAT number starting with FR. Confusing the two is the most expensive beginner error, because founders who wait for a Kbis they do not need start trading months late on the VAT track while the fifteen-day clock already runs.

B. How the French VAT number is issued, and why businesses outside the European Union must appoint a representative in France

The French VAT number of a domestic company arrives almost by itself. The public service portal explains that the SIE automatically sends the business its intra-Community VAT number upon registration. A company created in France therefore receives its FR number when it is registered, without a separate application, while a business outside the automatic circuit must request its number online through the professional-account messaging service on impots.gouv.fr. For a foreign business without a French establishment there is no SIE and no automatic issue, so the file goes to the specialist office. The customs administration directs every business required to register for French VAT to a single competent office, the SIEE, the foreign-business tax office within the DINR, the non-residents tax directorate. That single sentence fixes the geography of every foreign file: one competent office in France, the SIEE, whatever your home country and whatever the place of your French operations. From there the paths of European and non-European businesses split sharply, and choosing the wrong path is the second most expensive beginner error. Businesses established in another European Union member state register directly with the French administration and may, if they wish, entrust a tax agent with their formalities. operators established in another European Union Member State without a French establishment must register, declare the French transactions and where relevant pay the tax in France, and they may entrust some or all of those declaration and payment formalities to a French-established tax agent. The mandataire fiscal, the tax agent, is therefore an option for European businesses, a convenience that centralises returns and payments but does not replace the operator as the taxpayer. Businesses established outside the European Union have no such option. For operators established outside the European Union the same sources impose a harder duty: they must appoint a French-established fiscal representative who completes their formalities and pays any VAT due for them, a duty the customs guidance anchors in Article 289 A of the Tax Code for non-EU companies carrying out taxable or reportable transactions in France, and the public portal states it as a flat rule for any business outside the Union with taxable French operations. The représentant fiscal, the fiscal representative, is a French-established taxable person who files in your place and pays the VAT for you, which means the administration holds a solvent domestic contact for every euro you owe. The designation is not a private label on a letterhead. It is a written mandate accepted by a French taxable person, notified to the SIEE, and it exposes the representative alongside the operator, so reputable representatives audit your flows before signing and price their guarantee accordingly. Two narrow reliefs exist and both are fenced. First, the duty does not apply to businesses established in a non-European state with which France has a mutual assistance instrument comparable to the European recovery and administrative cooperation framework, the list of such states being fixed by ministerial order, so check the current order before relying on this relief, because treaty coverage changes and the SIEE applies the list strictly. Second, businesses carrying out only operations that dispense them from payment or exempt operations may instead use a one-off representative, a French-established taxable person accredited by the SIEE, for the filing duties of the transaction concerned. Outside these two cases, a non-European business that trades in France without a notified representative is not merely late, it is structurally non-compliant, and the portal warns that the VAT number can be invalidated where the representation duty is ignored. An invalidated number cascades immediately: customers can no longer validate it on VIES, the reverse charge of your European suppliers fails, customs blocks deferral, and every new invoice restarts the dispute. That is why systematic verification matters: check the VAT number shown on every invoice before each transaction, starting with your own once issued and each customer’s before applying the reverse charge, keep dated screenshots of the VIES replies in the file, and re-check periodically, because a number valid in January can be struck off by December. The identification duty also survives situations where intuition suggests it should lapse. Registration stays compulsory for a foreign company with no French establishment wherever it owes the tax, notably on sales to customers not identified for French VAT, or wherever it must complete French filing duties such as intra-Community acquisitions or deliveries, export deliveries and regime 42 import-and-resale chains. Sales to French private individuals, intra-European movements through France and the well-known regime 42 import-and-resale chains all keep the registration alive even when the business feels it merely transits. Map every flow on paper before concluding that you fall outside, and keep that map in the file, because the SIEE will ask for exactly that picture at the first control.

II. How Do You Register, Appoint a Representative and Invoice Correctly From Abroad?

A. Registration, representative and returns in practice, and what the February 2026 FedEx ruling changes

Work the file in order and the whole procedure fits on one page. First, qualify each French flow under the place rules of part I: goods located in France at dispatch, services to French taxable customers, services to French private individuals, imports from outside the Union, exports out of the Union. For each flow note whether the reverse charge of Article 283 of the French Tax Code applies, because every flow covered by a valid reverse charge is a flow that needs no registration for that operation. Second, choose the representation track. A European business files with the SIEE directly or through a mandataire fiscal of its choice. A non-European business signs a written mandate with a French-established taxable person willing to act as représentant fiscal, , who undertakes to complete the operator’s formalities and to pay any VAT due in its place. Negotiate that mandate as the serious contract it is: scope of operations covered, duration, fee, guarantee or deposit, information duties on both sides, termination notice and handover of records. A representative who signs blindly is a danger to you, because its failure becomes your assessment, and a representative who asks for your contracts, warehouse records and customer VAT numbers before signing is a professional doing its job. Third, file the identification declaration within the fifteen-day period of Article 286 of the French Tax Code: « Dans les quinze jours du commencement de ses opérations, souscrire au bureau désigné par un arrêté une déclaration conforme au modèle fourni par l’administration. » For a business without a French establishment that office is the SIEE, and the declaration states the identity of the operator, the nature of the French operations, the representative or agent where one is required or chosen, and the bank details for payments and refunds. Prepare from abroad a complete exhibit pack: home-country certificate of incorporation with sworn translation, proof of the home VAT or tax number, identity and powers of the signatory, the signed representation mandate, warehouse or logistics contracts proving the French footprint, and specimen customer contracts showing the place of each flow. Files stall far more often on missing exhibits than on legal debate, and a complete pack filed in week one beats a perfect memo filed in month three. Fourth, run the returns. Article 287 of the French Tax Code provides: « 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 et dans le délai fixé par arrêté une déclaration conforme au modèle prescrit par l’administration. » Operators under the standard real regime file the CA3 monthly, reporting total operations and the detail of taxable ones, and pay the VAT due each month, with quarterly filing tolerated where the annual VAT due stays below 4,000 euros: « Lorsque la taxe exigible annuellement est inférieure à 4 000 €, ils sont admis à déposer leurs déclarations par trimestre civil. » Calendar the deadlines in the home office as well as with the representative, because the representative files on your figures and late figures mean late filings. Our guide on missed French VAT returns, penalties and fixes from abroad details what a single missed CA3 costs and how to repair it, so treat that piece as the operating manual of this section. Fifth, invoice to the French standard. Article 289 of the French Tax Code imposes: « 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 » Every taxable supply to another taxable person or non-taxable legal person must produce a compliant invoice showing both parties’ VAT numbers including your new FR number, and reverse-charge invoices must carry the explicit mention that the customer accounts for the tax. Our companion on billing French clients without a French VAT number walks through the correction of past invoices line by line. Sixth, plug the file into electronic invoicing and electronic reporting, mandatory in France from 1 September 2026, as explained in our e-invoicing guide for foreign companies selling in France: a foreign operator identified in France is inside the reform, not outside it, and the representative or agent should confirm which platform and which format will carry your invoices. The February 2026 ruling of the Cour de cassation then sets the standard every mandate must meet. In that case the customs investigation services pursued FedEx International France for 1,940,162 euros of VAT assessed on 25 January 2019 over imports whose exporter was an American company that could not itself act as declarant, the Paris Court of Appeal ruled for the administration on 17 June 2024, and the commercial chamber quashed that ruling on 11 February 2026, pourvoi number 24-18.748, ECLI:FR:CCASS:2026:CO00070, decision published to the Bulletin. The Court restated the governing principle in terms every foreign operator should memorise: « la représentation en douanes doit être expresse et ne se présume pas. » It recalled the customs definition word for word: « Le représentant doit déclarer agir pour la personne représentée, préciser s’il s’agit d’une représentation directe ou indirecte et posséder un pouvoir de représentation. » and the consequence of missing powers: « La personne qui ne déclare pas qu’elle agit au nom ou pour le compte d’une autre personne ou qui déclare agir au nom ou pour le compte d’une autre personne sans posséder un pouvoir de représentation est réputée agir en son nom propre et pour son propre compte. » The appeal court had treated the French declarant as an indirect representative of the American exporter by presumption, even though the declarant denied holding any direct or indirect authority, and the Supreme Court held that reasoning unlawful: representation can never be inferred from the mere need for a local declarant. The VAT lesson for your file is direct. Your fiscal representative’s mandate must be express, written, precisely scoped and accepted before the first taxable operation, stating whether it covers direct or indirect representation and which operations it covers. A logistics provider that merely moves your goods is not your fiscal representative by implication, a freight forwarder that files a customs declaration without a representation clause does not become one by conduct, and an e-mail saying handle the French formalities will not survive a control. Sign the mandate first, notify it to the SIEE, keep the acceptance, and make sure every declaration states the capacity in which it is filed. At almost two million euros for one missing authority, the FedEx file prices informality better than any lecture.

B. How to fix past mistakes from abroad: late registration, wrong invoices and reverse-charge errors

Most foreign businesses discover the French VAT duty after trading, not before, and the repair follows the same order as the registration, only backwards. Start with the calendar. List every French operation since the first one: warehouse entries and exits with dates, domestic sales from French stock, services billed to French customers with their VAT numbers or their absence, imports with customs declarations, exports with proof of exit. Against each line write the place rule that located it in France, goods in France at dispatch under Article 258 of the French Tax Code, services to a French taxable customer under Article 259 of the French Tax Code, imports under Article 291 of the French Tax Code, and mark whether the reverse charge of Article 283 of the French Tax Code genuinely applied. That table is the file: it tells the SIEE when the fifteen-day period of Article 286 of the French Tax Code started running, which returns are missing, and which invoices must be corrected. Then register without waiting for the table to be perfect. File the SIEE identification with the representative mandate for non-European businesses or directly or through a tax agent for European ones, because every additional month of unregistered trading adds returns, interest and questions, while a filed registration converts the past into a manageable catch-up. File the missing returns next. Article 287 of the French Tax Code requires every identified operator to file the prescribed return within the fixed period, and late returns draw the standard arsenal of surcharges and interest on top of the tax itself, as our guide to missed CA3 returns quantifies with the current rates and the spontaneous-regularisation reductions. Pay the principal with the return wherever cash allows, because interest runs on the unpaid tax and a paid principal shrinks every subsequent negotiation, including requests for leniency and payment plans. Correct the invoices in parallel. Where you billed French VAT without a French number, or billed without VAT where French VAT was due, reissue compliant invoices under the duty of Article 289 of the French Tax Code, showing your new FR number and the correct tax treatment, and follow the credit-note and replacement-invoice sequence our correction guide details, so customers can recover their input VAT and stop pressing you for valid documents. Treat reverse-charge errors as a separate workstream. Where you charged French VAT on supplies that belonged in reverse charge because the customer held a French VAT number, the correction passes through credit notes and re-billing without tax with the proper mention, plus alignment of both parties’ returns. Where you applied the reverse charge to customers without a valid French VAT number, the shelter of Article 283 never existed, since the tax « 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 », and the VAT becomes your debt with your number on the corrected invoice. Pull dated VIES evidence for every customer number you relied on, because a screenshot beats a memory in front of an inspector. Imports deserve their own check. Where goods entered France while you were not identified, Article 1695 of the French Tax Code made the VAT due at the border, and the file must reconcile each customs declaration with the corresponding domestic return after identification so no import is taxed twice or never. Where a declarant acted at the border on your behalf, verify the capacity stated on each declaration against the FedEx standard: express written authority, direct or indirect mode specified, acceptance on file. A forwarder that cleared goods in its own name without your mandate may have created a parallel liability that the control will surface, and discovering it in your own review costs a correction while discovering it in the inspector’s review costs a dispute. Keep the proof of exports with the same care. Article 262 of the French Tax Code exempts goods shipped outside the European Union, but only documented exits earn the exemption, so attach transport contracts, forwarder attestations and customs exit confirmations to each exempt line. Finally, organise the records the way the administration keeps them. Returns, invoices, VIES screenshots, warehouse statements, transport proofs, the representation mandate with its SIEE acceptance, and the correspondence with the representative live in one chronological file per year, retained for the control period and producible from abroad within days. Businesses that answer a SIEE questionnaire in three weeks with a complete file routinely close it; businesses that answer in three months with fragments invite an on-site logic of suspicion. Where the historical exposure already looks heavy, several unfiled years, systematic missing numbers, a terminated representative that never handed over records, instruct counsel before the first spontaneous filing rather than after the first assessment, because the order of disclosure shapes penalties, and penalties on multi-year VAT debts decide whether the French market stays profitable. For the wider tax picture around your French flows, from the 25 percent corporate income tax to branch against subsidiary arbitrage, our corporate tax guide for foreign owners completes this VAT manual.

Conclusion

A foreign business does not need a French company to need a French VAT number, and waiting for a company it will never create is how fifteen days become three years of exposure. Goods in France at dispatch, services located in France, and imports into France each trigger the French tax under Articles 256, 258, 259 and 291, exports alone leave it under Article 262, and the reverse charge of Article 283 shelters only supplies to customers that genuinely hold a French VAT number. Registration runs to the SIEE of the non-residents directorate within fifteen days of the first operation under Article 286, returns follow monthly or quarterly under Article 287, invoices comply under Article 289, and non-European businesses file and pay through a French-established fiscal representative whose express written mandate the February 2026 FedEx ruling makes a condition of survival rather than a formality. Register now through the correct track, verify every number on VIES, keep the mandate and the movement proofs in one file, and repair the past return by return and invoice by invoice. The French market rewards operators who treat its VAT as an entry ticket bought on day one, not as a fine negotiated on day one thousand.

Need a quick opinion on your case

Selling in France without a French company raises registration, representative and invoicing questions that turn on your exact flows, warehouses and customer numbers. Our firm offers a telephone consultation within 48 hours with a lawyer of the firm to review your contracts, invoices and customs documents and set the strategy before the next deadline. Call +33 6 46 60 58 22 or write through our contact page with your documents attached.