You live in London, New York, Dubai or Singapore, and your French company has just received its Kbis — the official identity certificate issued by the greffe, the registry of the commercial court, which proves that the company exists. Clients ask for your French VAT number, your accountant mentions a monthly return called CA3, and a supplier warns you that without a number starting with FR, it will keep charging its own VAT. Many foreign founders discover at this point that the Kbis alone settles nothing for value added tax: registration for VAT (taxe sur la valeur ajoutée, TVA) follows its own rules, its own thresholds and its own calendar, and the company can owe French VAT even when its owner never sets foot in France. This guide explains, for a business reader managing from abroad, when a foreign-held business becomes liable for French VAT, how to register without living in France, how to charge, file and pay on time, and how to challenge a reassessment when the French tax administration (direction générale des finances publiques, DGFIP) sends a bill you dispute. Each French acronym is explained on first use, and every decisive statement is anchored to an official source: the French Tax Code (code général des impôts, CGI) on Légifrance, the official tax commentary (Bulletin officiel des finances publiques, BOFiP), the Service-Public business portal, and two 2024 judgments of the commercial chamber of the Cour de cassation, France’s supreme court for civil and commercial matters. Readers looking for the broader incorporation sequence — bank account, Kbis, first hire — can start with our step-by-step guide to setting up a company in France as a foreign founder before returning here for the VAT layer.
I. Do you need French VAT at all? Finding your registration route from abroad
A. Which foreign businesses become liable for French VAT, and the franchise en base trap that catches small turnovers
French VAT applies to supplies of goods and services made in France by a taxable person acting as such, to intra-EU acquisitions and to imports, under Articles 256 and following of the CGI. A company incorporated in France — typically a société par actions simplifiée (SAS, simplified joint-stock company) or a société à responsabilité limitée (SARL, limited liability company) — is a French taxable person from its registration, even if its shareholder and its president live abroad. But liability does not stop at French companies: a foreign company with no French entity can still owe French VAT when it carries out taxable transactions on French territory, for example installation or assembly deliveries, domestic resales of goods located in France, or services deemed supplied in France under Article 259 C of the CGI, to which the official commentary expressly refers for transactions taxed in France performed by a non-EU taxable person (CGI, art. 259 C on Légifrance). The first question is therefore never where the owner lives, but where the transaction is deemed to take place and who is designated as the person liable (redevable) — a designation governed notably by Article 283 of the CGI, which allocates liability between supplier and customer, including reverse-charge (autoliquidation) situations where the customer accounts for the tax.
Small turnovers benefit from a simplification called the franchise en base: as the Service-Public portal explains, the franchise en base exempts businesses from declaring and paying VAT on the sales and services they provide. This regime applies to businesses established in France or in another EU Member State whose prior-year turnover stays below statutory ceilings. For 2026, the applicable French franchise ceilings stay unchanged. The abandoned reform is worth noting because many English-language guides still mention it: the proposal from the 2025 Finance Law to set a single 25,000-euro franchise threshold was dropped. The thresholds in force, set by Article 293 B of the CGI, are 85,000 euros for the previous calendar year for sales of goods, with an upper tolerance threshold of 93,500 euros for the current year, and 37,500 euros with an upper threshold of 41,250 euros for services. Cross the upper threshold and the protection disappears immediately: the business becomes liable from the first day of the overrun, not from the following year. The surrounding provisions — Article 293 B ter, Article 293 C, Article 293 E and Article 293 F of the CGI, together with Article 293-0 B of the CGI — frame the options to leave or opt out of the regime, so the decision should be taken with the full maze in view rather than on the headline thresholds alone.
The trap for foreign founders is the interaction between this franchise and cross-border trade. A business under the franchise is in principle not required to hold an intra-EU VAT number, yet a business that carries on intra-EU trade can be forced to register for VAT. Worse, giving your number to an EU supplier has an irreversible effect for the year: as Service-Public warns, sending its number to that supplier brings the franchise regime to an end. In practice, the Paris subsidiary that buys stock from a German supplier and casually transmits its FR number to obtain zero-rated invoicing can lose the franchise altogether. Before requesting any number, check whether the intended purchases and sales truly require it, because once the number circulates, the simplification is gone.
B. How to register from abroad: the tax office, the fiscal representative and the intra-EU number
At incorporation, the company is identified through the Guichet unique, the single online window operated by the Institut national de la propriété industrielle (INPI, the French industrial property office), which forwards the file to the greffe, to the tax administration and to the national statistics institute that allocates the SIREN and SIRET identification numbers. VAT identification is then handled by the service des impôts des entreprises (SIE, the business tax office) competent for the registered office — in practice, the SIE of the Paris arrondissement where the seat is domiciled for a Paris company. EU-based businesses without a French establishment appoint a representative (mandataire) in France; businesses established in a non-EU State with which France has a mutual-assistance instrument comparable to the EU recovery and administrative-cooperation framework may use the permanent representative provided for in Article 95 of Annex III to the CGI. The dividing line that matters most for founders outside the EU is stricter: they must go through an accredited fiscal representative (représentant fiscal).
The official commentary states the rule plainly: under Article 289 A(I) of the CGI, a person established outside the EU who is liable for VAT or must meet filing duties must have an accredited fiscal representative, a taxable person established in France, who undertakes to complete that person’s formalities and, for taxable transactions, to pay the tax in its place. The statutory basis is Article 289 A of the CGI. This representative, a taxable person established in France, files on the foreign business’s behalf and pays the tax in its place — which means the choice of representative is a decision about money, not paperwork: the representative’s accreditation and solvency condition the whole chain. Businesses not yet identified in France may alternatively, where they qualify, use the international agent (mandataire à l’international) created by Article 289 A bis of the CGI. Conversely, the old occasional (ponctuelle) fiscal representation has been abolished: the occasional-representation regime of Article 289 A(III) of the CGI was repealed by Article 112 of Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023, art. 112). A transitional tolerance applied — the VAT registration numbers of the occasional fiscal representatives concerned stayed valid until 31 December 2025 — but any structure still resting on an occasional representative must now migrate to permanent representation, registration, or the international-agent mechanism, and complete its French VAT registration to obtain its own number. Accreditation is not a rubber stamp: the representative must be a taxable person established in France, chosen by the foreign business and formally accredited, and it answers for the tax in place of the principal, which is why serious representatives ask for guarantees before signing. Businesses established in an EU Member State, or in a non-EU State bound to France by an equivalent mutual-assistance instrument for recovery and VAT cooperation, may instead appoint a permanent representative for one-off or recurring transactions. The mandate should be documented before the first taxable transaction, because the administration attributes each return and each payment to the mandate on record. For operators caught mid-migration, the administration exceptionally tolerates continued use of an occasional representative after 1 January 2026, but only for businesses that started French VAT registration formalities before 31 December 2025 and only until their own French VAT number is issued.
That number is the intra-EU VAT number (numéro de TVA intracommunautaire), built from the FR prefix plus the SIREN-based key. Service-Public states the principle plainly: holding an intra-EU VAT number is mandatory for a business liable for VAT. The application runs online through the professional account on impots.gouv.fr: click “Messagerie”, then “Écrire”, then “TVA” and finally “Je demande un numéro de TVA intracommunautaire”. Once issued, the number must appear on invoices for intra-EU supplies and can be checked by any counterparty in the VIES system (VAT Information Exchange System, the EU database that validates VAT numbers across Member States). Use the same reflex in reverse and check suppliers’ numbers before zero-rating a purchase: a valid number in VIES is the cheapest fraud screen a cross-border business has. Refusal or delay is not the end of the road: complete the file with the SIE, keep proof of each message sent through the professional account, and have the fiscal representative or agent follow up, because every month without a usable number is a month of cash-flow friction with suppliers and customers who need a valid FR number to apply the correct VAT treatment.
II. Charging, filing and paying French VAT from abroad, and contesting the bill
A. Invoicing, returns and payment: the CA3 rhythm, the simplified instalments and import self-assessment
Once registered, the business must invoice under French rules. Transactions carried out in France by a non-EU taxable person must be supported by invoices issued under the conditions of Article 289 of the CGI, and the representative or business must also file the client recapitulative statement (état récapitulatif des clients) provided for in Article 289 B of the CGI for intra-EU supplies of goods. Mandatory invoice particulars — sequential numbering, dates, identities and VAT numbers of both parties, quantity and nature of the goods or extent of the services, taxable base per rate, VAT amount, and where applicable the reverse-charge wording — apply regardless of where the manager sits. A Paris company run from abroad issues exactly the same invoice as a company run from the next street; distance changes nothing in the formal requirements, and defective invoicing is one of the most frequent findings in audits.
Returns follow one of two rhythms. Under the standard (réel normal) regime, the business files return No. 3310-CA3, monthly or quarterly depending on the VAT payable, and pays the balance on filing. Under the simplified (réel simplifié) regime, it pays two instalments (acomptes) computed on the previous year’s tax — the first in July at 55% of the previous year’s tax and the second in December at 40% — then files an annual return and pays or recovers the balance. Businesses that paid little last year escape the instalments entirely: a business that paid less than 1,000 euros of VAT the previous year is excused from instalments the following year. When the franchise ceilings are crossed mid-year, timing is tight: the business moves to the standard regime retroactively to 1 January of the overrun year, and that return must be filed in the month following the month (or quarter) of the overrun. From abroad, the practical lesson is to calendar these dates in the head office’s own system rather than relying on the French accountant’s reminders alone, because late filing triggers surcharges and interest that compound a dispute before it even starts. Instalments are not carved in stone either: a business that expects its VAT bill to move by more than 10% up or down can ask for the instalment amounts to be adjusted instead of absorbing a large balancing payment, and it can skip an upcoming payment by sending the SIE a dated and signed statement before the collection date where amounts already paid cover the tax due. For a business created during the year, turnover is scaled up pro rata to a full twelve months before testing the franchise ceilings, so a strong first half-year can push a young company into the standard regime sooner than its calendar-year figures suggest.
Imports deserve special attention because the collection mechanism changed. When goods enter France from outside the EU, the importer must self-assess the import VAT (TVA à l’importation, TVAI). The administration confirms the cash-flow effect: import VAT is no longer paid to customs at clearance; it is collected and deducted on the monthly or quarterly VAT return No. 3310-CA3 filed with the DGFIP. One exclusion matters for small structures: businesses under the simplified VAT regime cannot use import VAT self-assessment. Two judgments of the commercial chamber of the Cour de cassation, both delivered on 24 January 2024, show why identifying the correct debtor at import remains decisive. In the first (Cass. com., 24 January 2024, pourvoi No. 21-17.776, ECLI:FR:CCASS:2024:CO00031, partial cassation), the Court held that a customs broker acting under an indirect-representation mandate given by the person named as real consignee on the import declaration is jointly a debtor of the import VAT alongside the person liable, and benefits from the statutory security waiver of Article 114(1 bis) of the Customs Code In plain terms: the customs broker (commissionnaire en douane agréé) acting under an indirect-representation mandate for the real consignee shares debtor status and the statutory security waiver — and a broker acting under direct representation but using its own removal credit (crédit d’enlèvement) is treated the same. In the second (Cass. com., 24 January 2024, pourvoi No. 22-13.103, ECLI:FR:CCASS:2024:CO00032, rejection), the Court recalled that Article 1695(I) of the CGI collects import VAT like customs duties Foreign importers should therefore verify, line by line, who the customs declaration names as consignee and under which mandate the broker acts: if the broker defaults, as the insolvent broker did in both cases, the recovery notice (avis de mise en recouvrement, AMR) lands on the real owner of the goods.
B. Audits, reassessments and remedies when the owner lives abroad
VAT control typically starts with a desk review or an on-site audit by the DGFIP, sometimes prompted by inconsistencies between CA3 returns, the client recapitulative statements and the EU counterparts’ mirror data. When the administration disagrees, it issues a rectification proposal (proposition de rectification) detailing the legal basis and the amounts, then, absent acceptance, a recovery notice. The BOFiP documents a dedicated control framework reaching the fiscal representative itself, organised around Article L.10 BA of the Livre des procédures fiscales (the LPF, the code governing tax procedure): appointing a representative therefore does not shield the foreign business, and it exposes the representative, which is why reputable representatives demand collateral or standing guarantees before accepting the mandate. Throughout the procedure, one judicial safeguard carries real weight. In pourvoi No. 22-13.103 the Cour de cassation approved the rule that where unpaid duties were declared by the debtor or its representative and the administration does not dispute their amount, the rights of the defence do not require a prior adversarial exchange before issuing the recovery notice. Read carefully, this is a double-edged holding: where the amount was simply taken from the taxpayer’s own declaration, the administration may issue the recovery notice without a prior adversarial exchange — but where it questions, recharacterises or reassesses the amount, the rights of the defence apply in full, and a recovery issued without giving the taxpayer a real opportunity to be heard is vulnerable. From abroad, the operational consequence is to file complete, consistent declarations: every figure the administration can merely “validate” narrows the room for a defence based on procedural irregularity, while every figure it must reconstruct opens that door.
Contesting follows a staged path that can be walked entirely from abroad with proper representation. First, send a formal claim (réclamation contentieuse) to the competent SIE, identifying the tax, the period, the legal grounds — wrong person held liable, franchise wrongly denied, reverse charge ignored, import VAT already self-assessed on the CA3 — and attaching the invoices, contracts, customs declarations and proof of the representative’s mandate. Second, if the administration rejects expressly or stays silent past the statutory period, bring the case before the court: VAT assessment disputes belong to the administrative court (tribunal administratif), while recovery of customs-collected duties historically went to the judicial judge, as both 2024 cases illustrate — customs recovery notices litigated through the civil and commercial chamber of the Rouen Court of Appeal up to the commercial chamber of the Cour de cassation. Choosing the wrong forum wastes months, so the nature of the contested act (assessment versus customs recovery) must be identified before filing. Third, preserve the evidence chain from day one: the mandate given to the broker or representative, the credit used at removal, the names on the customs declaration, the CA3 lines where import VAT was collected and deducted. The two 2024 judgments turned precisely on such documents — who was named as real consignee, which mandate the broker held, whose removal credit cleared the goods. A founder in another country cannot reconstruct these papers after the fact; the file must be assembled as operations happen, kept in French or with certified translation, and stored where counsel in France can reach it within days, not weeks.
Conclusion
French VAT reaches further than most foreign founders expect: a French company is liable from birth, a foreign company becomes liable as soon as its transactions localise in France, and the franchise en base protects only turnovers that stay beneath 85,000 or 37,500 euros with no intra-EU number in circulation. Non-EU businesses must secure an accredited fiscal representative under Article 289 A of the CGI, obtain the FR-prefixed intra-EU number through the professional account on impots.gouv.fr, invoice to the standards of Article 289, and file the CA3 on its monthly or quarterly rhythm — self-assessing import VAT on that same return. When the administration reassesses, the defence runs on documents and deadlines: a reasoned claim to the SIE, then the right court, with the broker mandates and declaration lines that the Cour de cassation scrutinised in January 2024. Handled this way, from Paris or from the other side of the world, VAT becomes a managed compliance line rather than the notice that freezes the company’s account.