You run a company in London, New York, Dubai or Singapore, and France is your next market. Goods cross the border, a French customer asks for an invoice with French VAT, or your carrier sends a bill for import VAT you never expected to pay. At that moment, one question decides everything: does your foreign company need its own French VAT number, and who pays the tax if the paperwork is wrong? This guide answers that question from abroad, step by step: when registration becomes compulsory, how to obtain an intra-Community VAT number without opening an office in France, when the reverse charge shifts the tax to your customer, what a compliant invoice must show, and how to fix the two most expensive mistakes — import VAT billed twice and a reassessment served on the wrong person. The court rulings mentioned below are public facts about the parties they name; the guidance that follows is general in scope: it describes the checks that are useful in any comparable situation and does not describe the situation of those named companies, about which this article makes no finding.

I. Your foreign company needs a French VAT number earlier than most founders expect

A. Which sales in France force a foreign business to register for VAT?

French VAT catches every supply of goods and every provision of services made for consideration by a taxable person acting as such. The French Tax Code (CGI, the Code général des impôts) states it plainly: “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.” The place where your company has its registered office does not protect it. What matters is where the transaction is deemed to take place, and France deems a long list of cross-border transactions to take place on its territory.

The French tax administration summarises the trigger in one sentence on its official registration page for foreign businesses, which states the trigger plainly: a business with no fixed establishment in France that carries out any of the listed transactions must register for French VAT and obtain an individual identification number. An établissement stable is a fixed establishment, a real operational presence such as an office, a warehouse or a workshop with staff and equipment. If you have none in France and you still carry out any of the listed transactions, you must register for VAT in France and obtain an individual identification number, the well-known intra-Community VAT number starting with FR.

The transactions that most often trap foreign founders are the following. First, selling goods located in France to French private individuals or to buyers who are not identified for VAT in France: the VAT collected must appear on French VAT returns and be paid whenever the VAT collected exceeds deductible VAT. Second, shipping goods from France to another European Union member state, which is an intra-Community supply, including mere transfers of your own stock between two countries. Third, exporting goods out of France. Fourth, distance sales of goods shipped from another member state to private individuals in France, subject to the European small-operator scheme: below a combined annual threshold of 10,000 euros excluding tax for all intra-Community distance sales plus certain electronic services, a business established in a single member state may escape registration, but above that line registration becomes compulsory. Fifth, self-assessed VAT on imports, the autoliquidation (reverse charge at import), for which registration has been compulsory for these operations since 1 January 2022. Sixth, self-assessed VAT on purchases of goods or services from a supplier that is not established in France, once the company is already registered in France for customs purposes.

Imports deserve special attention because they generate the costliest misunderstandings. The Code provides that “Les importations de biens sont soumises à la taxe sur la valeur ajoutée.” And an import is defined as “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”, in other words goods arriving from outside the Union that have not yet been cleared for free circulation. Every container from China or the United States entering through Le Havre, Marseille or Roissy therefore creates a French VAT event, and someone must declare it. Since 1 January 2022 that someone is normally the importer itself on its French VAT return, the CA3 (the standard French VAT return form), rather than the carrier at the border. Foreign founders who keep thinking in pre-2022 terms, when an individual authorisation was needed and customs collected the tax at the gate, systematically misread their carriers’ invoices, as the court case examined in the second part of this article demonstrates.

Services follow a different territorial logic, and it produces a mirror image of the same trap. For business-to-business services, the place of supply is in principle where the customer is established. The Code states that “Le lieu des prestations de services est situé en France” whenever the customer is a taxable person with its business seat, a fixed establishment receiving the services, or failing that its domicile or habitual residence in France. A consultant in New York billing a French operating company, a software vendor in London invoicing a French distributor, or a Dubai holding company charging management fees to its French subsidiary are all, in principle, making supplies located in France. Whether that means registering for French VAT or applying the reverse charge depends on the next question, examined below. The official English-language page of the French administration confirms the starting point: when a taxable company established in France buys services from a seller in another member state, the service is subject to French VAT, and the applicable rules then turn on the tax regime of the French customer, the country of taxation, the nature of the service and whether the seller holds an intra-Community VAT number in the customer’s country (VAT applicable to trade in services within the European Union).

Two practical consequences follow for a founder living abroad. First, the VAT analysis must be done before the first invoice and before the first shipment, because customs systems and marketplaces increasingly demand the FR VAT number upstream, and a missing number freezes goods or gets invoices rejected by French customers whose accountants refuse documents without a valid number. Second, the registration route is entirely separate from creating a French company: a British limited company, an American LLC or a UAE free-zone company can hold a French VAT number while remaining a foreign company, without a Kbis (the official company identity certificate issued through the greffe, the commercial court registry), without share capital and without a French director. Registration is a tax identity, not a corporate transformation. Founders who confuse the two either incorporate a SAS they do not need or trade for months without the VAT number they do need. If the broader question of setting up a French presence is also on the table, the firm’s general roadmap for foreign founders covers incorporation, bank account, Kbis, VAT and first hire in one place (setting up a company in France as a foreign founder), and this article takes over exactly where that roadmap leaves the VAT question open.

B. How to obtain the French VAT number from abroad: forms, offices and representatives

Registration runs through the French tax administration, the DGFIP (Direction générale des finances publiques, the Directorate General of Public Finances), and more precisely through the tax office dedicated to businesses with no establishment in France, the SIEE (Service des impôts des entreprises étrangères, the tax office for foreign companies). The official registration page designates that competent office and lists the supporting documents to file; the core of the file is the EE0 form, the registration declaration for foreign businesses, in which a company concerned by import self-assessment must state so expressly in the relevant boxes. Founders based in Paris or elsewhere in the Île-de-France region follow the same national procedure, since the competent office is centralised: the Paris specificity is practical rather than legal, with filings, correspondence and any in-person appointment concentrated in French, frequently through a French-speaking representative, an accountant or a lawyer, given time-zone gaps and language requirements.

The substantive clock starts as soon as activity begins. The Code provides that “Toute personne assujettie à la taxe sur la valeur ajoutée doit : 1° 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.” Every taxable person must therefore file the starting declaration within fifteen days of beginning operations, and the same provision requires a declaration when the business ceases. A foreign founder who makes a first taxable delivery in France and waits six months to regularise the position is already late, with interest and penalties accruing from the first transaction. Once identified, the business enters the normal return cycle: “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.” Businesses under the standard real-taxation regime file the CA3 return monthly, reporting total transactions and the detail of taxable ones, and pay the VAT due each month. The identification articles cited in that provision, 286 ter and 286 ter A, are precisely the ones that create the individual VAT number, so registration, identification and recurring returns form one continuous chain.

Companies established outside the European Union face one additional layer: representation. French import and VAT mechanics for third-country sellers historically run through a représentant fiscal, a France-based fiscal representative who performs the customs and declaration formalities for the foreign principal. A July 2025 judgment of the Paris judicial court shows why the choice of that representative, and the wording of its mandate, is a commercial decision with real money behind it (TJ Paris, chamber 9 section 1, 17 July 2025, RG 23/03217). In that case, 83 customs declarations covering mobile phones were drawn up between September and December 2021 by an international carrier acting as indirect representative before the Roissy customs office, for a Chinese company whose fiscal representative was a French services company. When the customs administration issued a recovery notice for the VAT, the fiscal representative argued that only the foreign company and the customs broker should answer for the debt, and asked the court to annul the notice. The court rejected the argument in full: “DÉBOUTE la société LOGEFI SERVICES de l’ensemble de ses demandes”, “CONFIRME l’avis de mise en recouvrement n°783/22S60”, and ordered the unsuccessful company to pay 3,300 euros under article 700 of the Code of Civil Procedure plus the costs. The lesson for a founder in Shenzhen, New York or Dubai is direct: whoever signs as your fiscal representative, and whoever your carrier names on the import declaration, determines who the administration pursues first, and unwinding that designation after a recovery notice is an uphill case. Put the allocation of the VAT debt in writing before the first shipment, check every declaration to see whose name appears as consignee, and keep the mandate letter of the representative together with the transport contracts.

Three file-building reflexes save months. First, apply as soon as the business model is fixed, not when the first problem appears, because the number is needed upstream by carriers, warehouses and customers. Second, describe the planned transactions precisely on the EE0 form — domestic sales, intra-Community supplies from France, distance sales, import self-assessment — since an incomplete description produces a number with the wrong scope and a second round of correspondence. Third, keep proof of everything the administration issues: registration confirmation, allocated FR number, filing receipts for each CA3. French VAT disputes are document disputes, and the company that cannot produce its own registration trail starts every discussion at a disadvantage.

II. Charging, reverse-charging and invoicing French VAT without paying twice

A. When your French customer pays the VAT for you: the reverse charge explained

The reverse charge, or autoliquidation, is the mechanism that most often surprises common-law founders, because it reverses the reflex learned at home: instead of the seller collecting VAT, the buyer declares both the VAT due and the corresponding deduction on its own return, so no cash changes hands for the tax. France applies it widely to cross-border supplies precisely to avoid forcing every foreign seller to register. The central provision states that “La taxe sur la valeur ajoutée doit être acquittée par les personnes qui réalisent les opérations imposables”, subject to the reverse-charge cases that follow, in which “la taxe est acquittée par l’acquéreur, le destinataire ou le preneur” where the supplier is established outside France and the buyer is a taxable person holding a French VAT number. Three conditions therefore coincide: the supplier is not established in France, the transaction is covered, and the buyer is itself a taxable person holding a French VAT number. The amount due is then identified on the return mentioned in article 287, the CA3 cycle described above.

The same article extends the logic to services supplied by businesses not established in France — services covered by article 259 supplied by a business not established in France, which are taxed on the buyer — and to intra-Community acquisitions of goods, where “la taxe doit être acquittée par l’acquéreur”, with the seller remaining jointly liable when the buyer is established outside France. In practice, a German company selling equipment to a French taxable distributor, or an Irish consultancy billing a French client company, invoices without French VAT and leaves the French customer to self-assess it. The U.S. founder billing a French operating company for management services stands in the same position, provided the French recipient is a taxable person with a French number. Conversely, the moment the customer is a private individual or a non-taxable body, the reverse charge is unavailable, the supplier must generally charge French VAT itself, and registration becomes unavoidable — which is exactly the distance-sales and B2C-services trap described in the first part.

Invoicing is where the reverse charge succeeds or fails, because the invoice is the document both tax administrations read. The Code imposes a simple but absolute duty: “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 supplies to another taxable person or non-taxable legal person that are not exempt. A reverse-charge invoice must therefore exist, identify both parties with their VAT numbers, describe the supply, and carry the statement that the tax is due by the customer under reverse charge, so that the French buyer can book the self-assessed VAT and the foreign seller can prove it charged nothing. Invoices that mention French VAT “for information”, invoices with no VAT number, and invoices mixing French VAT and reverse-charge wording on the same line are the three documentary defects French auditors exploit first. The English-language service-public page confirms the surrounding framework for intra-EU services and should be worked through line by line before drafting invoice templates (VAT applicable to trade in services within the European Union), alongside the impots.gouv.fr registration page for the operations that require CA3 returns (Immatriculation à la TVA). Competitor guides aimed at French businesses, such as the legal publishers and company-formation platforms, generally describe the same rules from the French seller’s viewpoint; what they rarely give the foreign founder is the combined reading — registration scope, customer-side self-assessment and invoice wording in a single procedure — which is what this article provides.

One verification closes the loop on every new customer and every new supplier: check the validity of the counterpart’s intra-Community VAT number on the European VIES database before invoicing, record the result, and re-check periodically for recurring flows. A reverse charge applied to a customer whose French number is invalid at the invoicing date is a reassessment waiting to happen, and the administration will test precisely that point. The number check costs minutes; the dispute costs years.

B. When the paperwork has already gone wrong: double-billed import VAT and reassessments

The most instructive recent ruling for foreign supply chains comes from the Rennes Court of Appeal and concerns goods imported from China and the United States through an international carrier (CA Rennes, 3rd commercial chamber, 11 February 2025, RG 24/02101). A French importer of electronic components had its non-EU goods transported by a global express carrier acting as customs representative. The carrier then sued for payment of customs-duty and import-VAT invoices totalling over 34,000 euros, which it said it had paid on the importer’s behalf. The importer resisted for three invoices issued in February and April 2020, for 34,208.36 euros, arguing that it held an import-VAT self-assessment authorisation and had informed the carrier. The court reconstructed the file: “L’autorisation est donnée conformément aux II et III de l’article 1695 du code général des impôts”, covering all entries into France or the European Community of goods from China or the United States carried for its account, and email exchanges proved the carrier had known about the regime since at least early 2020, even assuring the importer in February 2020 that the necessary corrections had been made after a registration error. The outcome follows in plain terms: “les factures relatives à la TVA à l’importation ne sont pas dues par la société Cordon, soit les trois factures émises les 19 février, 22 avril et 27 avril 2020”, and the first-instance judgment ordering payment was reversed in full.

Three teachings matter for a founder organising imports today. First, import VAT is paid once: either the importer self-assesses it on its return or the carrier pays it at the border and re-bills it, never both, and a carrier that was informed of the self-assessment cannot pass on tax it should not have paid. Second, information must be provable: the importer won because emails, the framework transport contract and the Kbis-established identity of the carrier documented knowledge, not because the regime existed in theory. The burden rule the court recalled at the opening of its reasoning governs every VAT dispute: the party claiming performance of an obligation must prove it, and the party claiming to be discharged must prove payment or the discharging fact. Third, the legal landscape has moved on: the authorisation system discussed in the ruling belonged to the pre-2022 world, and since 1 January 2022 import VAT self-assessment runs through the CA3 return for registered importers, with registration compulsory for these operations as the impots.gouv.fr page states. A carrier invoice showing customs VAT for a period in which the importer self-assessed on its CA3 is therefore suspect by construction, and the first reflex is to compare the invoice dates with the CA3 lines before paying anything.

Reassessments follow the same documentary logic. The administration typically challenges the scope of registration, the validity of a customer’s number at the invoice date, missing reverse-charge statements, or VAT deducted without a compliant invoice. The defence file mirrors the attack: registration confirmation and EE0 description, VIES check records, complete invoice chains, CA3 returns showing the self-assessed amounts on the return provided for in article 287, and the transport and customs documents tying goods to declarations. The current Code frames the cash mechanics of imports for non-identified persons as follows: “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”, with customs-style recovery in those residual cases. Every other importer belongs on the CA3 track, and demonstrating that classification with dated returns is often the whole case. Where the administration persists, the assessment notice itself indicates the available remedies and their time limits, which must be read immediately and calendared without delay, since French tax litigation is strict on admissibility conditions and a late challenge fails regardless of its merits.

Finally, prevention remains cheaper than cure by an order of magnitude. Before the next shipment or the next invoice run, a foreign founder should confirm four points in writing: the company’s FR VAT number and the exact scope declared; the counterpart’s valid VAT number with a dated record; the correct VAT treatment per flow — French VAT charged, reverse charge by the customer, or exempt intra-Community supply — with the matching invoice template; and the identity of the person named on customs declarations, carrier, fiscal representative or importer. Those four confirmations, kept together with the returns, convert most future disputes into short correspondence instead of court cases.

Conclusion

A foreign company does not need a French subsidiary to face French VAT: a single taxable delivery, a distance sale above the threshold, an intra-Community movement of stock or one container through Roissy can create the obligation. Registration through the foreign-companies tax office is the entry ticket, the fifteen-day declaration rule sets the pace from the first transaction, and the monthly CA3 cycle carries the tax afterwards. The reverse charge then allocates each flow to the right taxpayer — customer rather than supplier — provided invoices say so and VAT numbers check out. And when a carrier bills import VAT that was already self-assessed, or a recovery notice lands on the representative instead of the principal, the answer lies in the documents: authorisations, mandates, emails, declarations and returns, read against the Code articles and the published rulings examined here. Organised upstream, French VAT is an administrative routine; discovered downstream, it is a reassessment. Founders who choose the routine keep their margins, their goods and their French customers.