{"id":2124488,"date":"2026-09-18T22:56:38","date_gmt":"2026-09-18T20:56:38","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/09\/18\/foreign-company-france-vat-number-registration-invoicing-refund-abroad\/"},"modified":"2026-09-18T23:01:29","modified_gmt":"2026-09-18T21:01:29","slug":"foreign-company-france-vat-number-registration-invoicing-refund-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/09\/18\/foreign-company-france-vat-number-registration-invoicing-refund-abroad\/","title":{"rendered":"Your French Company Has No VAT Number Yet and You Live Abroad: Registration, Invoicing, Refunds and How to Unblock From Abroad"},"content":{"rendered":"

You live in London, New York, Dubai or Singapore, your French company is registered, the Kbis<\/a> (the official identity card of a French company, issued by the commercial court registry, the greffe<\/em>) is in your inbox, and yet your accountant tells you that you still cannot issue a proper invoice: the French VAT number has not arrived. Your first French customer refuses to pay an invoice without VAT, your supplier charges you French VAT you cannot yet recover, and the tax office (service des imp\u00f4ts des entreprises<\/em>, the local branch of the Direction g\u00e9n\u00e9rale des finances publiques<\/em>, the French tax administration) asks for documents you do not have in French. This is the most common administrative blockage foreign founders meet after incorporation, and it is also the most expensive one when it drags on, because every week without a VAT number is a week of VAT you pay but cannot deduct and of invoices your customers will challenge. This guide explains, for a foreign owner running a French company from abroad, how the French VAT number is really issued, who must appoint a tax representative and who is exempt, how to invoice lawfully while the number is pending, how returns, deduction and refunds work once you are identified, which penalties strike first, and how to contest an assessment or unblock a frozen refund without boarding a plane. Every key rule below is anchored to the exact statutory text and to recent court decisions you can check yourself.<\/p>\n

I. Get your French VAT number from abroad without blocking your first invoices<\/h2>\n

The French VAT number (num\u00e9ro de TVA intracommunautaire<\/em>) is not issued at the same time as the company itself, and that time gap is where foreign founders get trapped. Understanding the chain from the one-stop shop to the tax office, and knowing whether you personally need a fiscal representative, decides whether you wait two weeks or four months.<\/p>\n

A. Registration, identification and the non-EU representative: who does what from abroad<\/h3>\n

Since 1 January 2023, every business formality in France passes through a single online portal, the guichet unique<\/em> (one-stop shop) run by the INPI, the French intellectual property and business formalities institute. The Code de commerce provides that this single body receives the full file for accessing and carrying on a business activity, as stated in article R. 123-1 of the Code de commerce<\/a>, and forwards it to the registries and administrations concerned. In practice, your file travels from the guichet unique<\/em> to the National Business Register (Registre national des entreprises<\/em>) which issues the SIREN and SIRET numbers (the nine-digit company identifier and its fourteen-digit establishment version), and the publication in the official bulletin of civil and commercial announcements, the BODACC (Bulletin officiel des annonces civiles et commerciales<\/em>), follows. The VAT number itself is then allocated by the tax office of the company’s registered address: it is built as FR, plus a two-digit computer key, plus the nine digits of the SIREN. The INPI describes this whole route on its official guichet unique page<\/a>, and the tax administration describes the resulting identifier on the official service-public.fr page devoted to the intra-Community VAT number<\/a>, which is the page your French customers will consult when they check you.<\/p>\n

Your first practical step from abroad is therefore to make sure the guichet unique<\/em> file was complete, because an incomplete file is the main cause of silent delays. Foreign founders are typically asked for a translated and sometimes legalised copy of their passport, proof of the registered address in France (domiciliation contract or lease), the articles of association, the list of directors, and the declaration of beneficial owners for the RBE register (Registre des b\u00e9n\u00e9ficiaires effectifs<\/em>). If the file bounces, no SIREN means no VAT number, and the tax office never even sees your case. If your bank account file is also stuck, which happens often to non-resident directors, read our companion guide on what to do when a French bank refuses your company’s account or freezes the capital deposit<\/a>, and our general step-by-step guide to setting up a company in France as a foreign founder<\/a>, which covers the bank account, the Kbis, VAT and the first hire in one place.<\/p>\n

Once the company exists, the tax code imposes a fast declaration duty. Article 286 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> (the French general tax code, CGI) requires every person liable to VAT to file a declaration with the designated office within fifteen days of starting operations, to supply all information about the professional activity, and to keep books and supporting documents, including purchase invoices, under the conditions of article L. 102 B of the Livre des proc\u00e9dures fiscales (the tax procedure code, LPF). For a foreign owner, the trap is the starting point of that fifteen-day period: the administration counts from the actual start of economic activity, not from the day you finally receive a letter with the VAT number. A company that already rents an office, signs contracts or makes taxable supplies while telling itself it is not yet identified is already late. File the declaration of existence and the VAT option paperwork through your accountant (expert-comptable<\/em>) as soon as the Kbis arrives, even if you are outside France: everything is filed electronically, and a scanned mandate is enough for the accountant to act.<\/p>\n

The second question is whether you must appoint a repr\u00e9sentant fiscal<\/em> (accredited tax representative) in France. The answer depends on where you are established, not on your nationality. Companies established in another European Union Member State identify directly with the French tax office for most operations and use the reverse-charge and refund channels described below, without a representative. Companies established outside the EU, and in particular American, British post-Brexit, Gulf or Asian companies with no French establishment that carry out taxable transactions in France, generally need an accredited representative who becomes jointly liable for the VAT, unless an international mutual-assistance instrument exists with their country. This is why a British founder who lived with direct identification before Brexit, or an American group selling through a French warehouse, suddenly discovers paperwork and guarantees that did not exist before the first shipment. If you have no French company at all yet and only carry out taxable transactions in France from abroad, start with our guide for foreign businesses registering for French VAT without a French company<\/a>, then come back here once the company exists and the missing number itself is the blockage. Ask your accountant in writing, before the first taxable operation, which category you fall into, and have the representative mandate signed and dated: backdating a representative after an audit starts does not erase the period without one.<\/p>\n

Two checks close this first stage. First, verify how your number appears to the outside world: any EU customer can validate a French VAT number on the European Commission VIES database, and a number that does not validate there will get your invoices rejected even if the French internal directory shows you as registered. Second, keep every proof of filing from the guichet unique<\/em>, the SIREN notification, the RBE filing receipt and the tax office correspondence in one file, in French or with certified translations, because the same bundle will be requested again at the first VAT refund claim and at the first audit. Founders who keep this bundle ready answer a tax office letter in days; founders who must rebuild it from abroad answer in months, and months cost penalties.<\/p>\n

B. How to invoice and charge French VAT while the number is still pending<\/h3>\n

The golden rule while the number is pending is simple: never invent a VAT number and never copy a neighbouring company’s format. An invoice with a false intra-Community number is worse than an invoice without one: it exposes you to fines for inaccurate invoicing, it makes your customer’s own deduction vulnerable, and it reads as fraud to an auditor. What you can lawfully do instead depends on whom you invoice.<\/p>\n

French law is strict about what an invoice must contain. Article 289 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> requires every taxable person to make sure that an invoice is issued, by himself, by his customer or by a third party, for supplies of goods or services to another taxable person or to a non-taxable legal person that are not exempt, for certain listed supplies, and for advance payments received before those operations are carried out. The detailed mandatory mentions, including the VAT numbers of both parties, the precise description, the price, and the VAT rate and amount, are what your French customers’ accountants check line by line. If your number is still pending, issue the invoice with your SIREN, your company name and address, and the mention that the intra-Community VAT number is being allocated, then send a corrective invoice or a clearly referenced supplement as soon as the number arrives. Agree this process with the customer in writing before invoicing: a customer warned in advance and holding your Kbis and your guichet unique<\/em> receipt will usually accept the invoice and pay; a customer surprised afterwards will suspend payment and blame you for his own accounting delay.<\/p>\n

Many cross-border situations do not require you to charge French VAT at all, which solves the waiting problem from the other side. The territorial backbone is article 256 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>, under which supplies of goods and services made for consideration by a taxable person acting as such are subject to VAT, combined with article 259 of the same code<\/a>, which places services where the customer is established when the customer is a taxable person acting as such with his economic seat in France. In that business-to-business pattern, and for supplies by a taxable person established outside France covered by article 259 A, the reverse charge applies: article 283 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> states the principle that VAT must be paid by the persons carrying out the taxable operations, subject to the suspension cases, and organises the situations where the customer, the recipient or the taker pays the tax instead of the foreign supplier. Concretely, if your French company, still waiting for its number, supplies services to a French VAT-registered customer, the compliant invoice generally states the reverse charge (autoliquidation<\/em>) with reference to the article, and the customer accounts for the VAT on his own return. Do not improvise this wording: one wrong mention turns a lawful reverse charge into an apparent omission to charge VAT, and have the treatment confirmed operation by operation, because goods, services to private individuals, and special schemes each follow their own place-of-supply rule.<\/p>\n

E-commerce and warehousing deserve a separate warning, because foreign founders massively underestimate them. If a non-EU company ships goods to French consumers through a French logistics platform, the import VAT becomes due at importation, and undervaluing the parcels to slip under an exemption threshold is treated as fraud, not as optimisation. The Paris Court of Appeal gave a vivid illustration on 17 June 2024 (RG No. 22\/01383, FedEx), where an American online seller routed Apple products from the United States to Amazon warehouses in France and Spain, declared them as negligible-value consignments worth less than 22 euros so as to benefit from an import VAT exemption, and left the carrier that had acted as indirect customs representative facing an assessment of 1,800,797 euros of evaded import VAT plus 133,180 euros of late interest. The court confirmed the first judgment in all its provisions, ordered no preliminary reference to the Court of Justice of the European Union, and left the carrier bearing the debt and the appeal costs. The decision recalls the background rule that a taxable person who facilitates distance sales of imported goods, in particular through an electronic platform, is liable for import VAT, with the real consignee remaining jointly liable, while noting that this platform-liability provision has applied only since 1 July 2021. For a foreign founder, the lesson is blunt: the 1 July 2021 e-commerce reform (One-Stop Shop, OSS, and Import One-Stop Shop, IOSS) is not optional decoration, the marketplace is now inside the VAT chain, and goods stored in France before sale to French consumers create French VAT obligations from day one, number or no number. Register for imports through an EORI number (the EU customs identification), use the IOSS or a representative where eligible, and never let a logistics partner file customs values you have not approved in writing.<\/p>\n

II. Keep your VAT position alive: returns, refunds, audits and how to fight back from abroad<\/h2>\n

Once the number arrives, founders often believe the danger is over. It is not: the French system taxes mistakes faster than it rewards compliance, and foreign-owned companies are audited on exactly the points where distance makes them weak, namely late returns, shaky deduction, and refunds claimed without a complete file. The second half of this guide follows the life of your VAT after identification.<\/p>\n

A. Returns, deduction, refunds and the penalties that hit foreign-owned companies first<\/h3>\n

The return rhythm is monthly by default under the normal real regime. Article 287 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> requires every VAT taxable person identified under the combined provisions of articles 286 ter and 286 ter A to file with his tax office, within the period fixed by order, a return on the model prescribed by the administration, and taxpayers under the normal real regime file that return monthly, showing the total amount of operations on the one hand and the detail of taxable operations on the other, with the tax due paid each month. From abroad, the operational consequence is that you need a standing organisation, not a wake-up call every month: a French accountant with a direct debit mandate (mandat de pr\u00e9l\u00e8vement SEPA<\/em>), a calendar of the filing dates for your specific tax office, and a rule that no invoice, purchase or bank movement stays untransmitted beyond the fifth day of the following month. Companies that send a shoebox of documents every quarter pay the price of that rhythm in late-filing surcharges and lost deduction.<\/p>\n

Deduction is the financial heart of the system, and the statute states it plainly. Article 271 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> provides that the VAT which has burdened the price components of a taxable operation is deductible from the VAT applicable to that operation, with the right to deduct arising when the deductible tax becomes chargeable. In plain terms, the French VAT you pay on rent, equipment, professional fees, goods for resale and subcontracts reduces the VAT you owe on your sales, and the surplus can be carried forward or, under conditions fixed by decree, refunded. The Cour de cassation (the French supreme court for civil, commercial and criminal matters) gave this neutrality principle a strong recent illustration in its Commercial Chamber judgment of 23 November 2022, appeal No. 21-13.613, published in the Bulletin, recalling that the Court of Justice of the European Communities held (ECJ, 3 March 2005, Fini H, Case C-32\/03) that operations carried out by a company during the liquidation period of its activity must be regarded as part of the economic activity, so that the common VAT system guarantees full neutrality as to the tax burden of all economic activities, whatever their purposes or results. The practical message for a foreign owner is that input VAT on serious business expenditure remains deductible even in unhappy periods, closure, restructuring or loss-making launch years, provided the expenditure genuinely relates to taxed activity and is documented. Keep every supplier invoice with its VAT breakdown, proof of payment, and, for intra-Community purchases, the supplier’s valid VAT number: deduction without an invoice is deduction refused, and a foreign supplier’s pro-forma document is not an invoice.<\/p>\n

Refunds (remboursements de cr\u00e9dit de TVA<\/em>) are where distance hurts most, because the administration systematically controls refund claims from young foreign-owned companies before paying. Expect the tax office to ask for the full invoice file, bank statements proving payment, contracts, and sometimes proof that your suppliers really exist. A refund claim filed from abroad with gaps, untranslated key documents, or invoices in the wrong name triggers a loop of questions that can freeze the money for six to twelve months. File refund claims only when the file is complete, answer each question within the deadline stated in the letter, and send documents by the official electronic channel so that every submission is timestamped. Never let a refund claim sleep: an unanswered request for documents is eventually read as an abandoned claim.<\/p>\n

Penalties, by contrast, need no reminder letter to accrue. Article 1728 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> punishes failure to file a declaration or act containing elements used for the base or the settlement of the tax within the prescribed deadlines with an increase applied to the duties due, and the same logic extends through late-payment interest month by month. For a company run from abroad, three penalties arrive first in practice: the surcharge for late monthly returns even when no VAT is finally due, the late interest on VAT paid late because the accountant received the documents too late, and the fines for invoicing irregularities discovered during a customer audit that bounces back to you. Add the customs side for importers: evaded import VAT draws the duties themselves plus interest, as the FedEx figures above show, and the customs representative who filed for you can turn against you for the sums it had to pay. The cheapest insurance against all of this is boring and foreign-founder-proof: monthly transmission to the accountant, direct debit for payments, and a rule that no invoice goes out and no invoice is paid without the VAT treatment checked.<\/p>\n

One calendar point is often missed by non-resident directors. French companies close annual accounts, file corporate tax, hold the annual meeting approving the accounts, and publish through the BODACC and the tax filings on a fixed yearly cycle, and VAT interacts with that cycle through year-end adjustments, credit carry-forwards and the reconciliation between declared turnover and accounting turnover. Any gap between the turnover in your VAT returns and the turnover in your financial statements is an automatic audit flag, and reconciling the two from another continent in the middle of an audit is painful. Ask your accountant for a one-page annual VAT-to-accounts reconciliation every year and keep it with the filed accounts: it answers the auditor’s first question before it is asked.<\/p>\n

B. Audits, frozen refunds and how to contest from abroad before the deadline kills you<\/h3>\n

A VAT audit (contr\u00f4le fiscal<\/em>) of a foreign-owned company usually starts quietly, with a request for documents or a notice of a desk audit (contr\u00f4le sur pi\u00e8ces<\/em>), and escalates only if the answers are late or inconsistent. The administration’s right to reassess is fenced by time: article L. 169 of the Livre des proc\u00e9dures fiscales<\/a> provides that for income tax and corporate tax the administration’s right of recovery runs until the end of the third year following the year for which the tax is due, with statutory exceptions, and VAT reassessments follow their own comparable limitation framework that makes old periods safe only once the deadline has truly expired. Concretely, keep every VAT-relevant document at least until all limitation periods covering it have run out, and never destroy the file of a year that is still under discussion, even if the local accountant changes. Founders who move accountants without moving the archive discover during the audit that neither the old nor the new accountant holds the complete file.<\/p>\n

When the administration notifies a reassessment (proposition de rectification<\/em>), the worst reflex from abroad is silence, and the second worst is an angry phone call. The procedure is written and adversarial by design: you have a fixed period, stated in the notice, to submit written observations, and those observations shape everything that follows, including the judge’s later reading of the file. Answer in French, point by point, with numbered exhibits, addressing each legal ground the administration invokes rather than the commercial fairness of your situation. Three arguments work better than ten scattered ones: the correct legal characterisation of the operation (place of supply, reverse charge, exemption), the completeness of your evidence (contracts, invoices, transport documents, payment proofs), and the proportionality of penalties (first breach, good faith, spontaneous regularisation). Attach the proof that you regularised as soon as you understood the issue: spontaneous correction before any audit notice is the strongest penalty-reduction argument in the French system, while correction after the notice arrives is merely useful.<\/p>\n

Frozen VAT refunds follow a parallel track. When the tax office neither pays nor formally rejects your refund claim, do not wait indefinitely: send a formal follow-up referencing the claim number and date, complete any pending document request even if you consider it excessive, and, if the freeze persists, file the formal claim (r\u00e9clamation<\/em>) that opens the path to the administrative court. Every assessment and every rejection carries its own appeal deadline printed on the notice, and those deadlines are strict: a day late is a case lost, whatever the merits. From abroad, the safe organisation is a single rule, which is that every letter from the tax or customs administration is forwarded to your lawyer and your accountant on the day it arrives, by scan, with the envelope showing the date. French tax litigation turns on dates, and the founder who can prove when each letter arrived wins the deadline battles that decide half of all cases.<\/p>\n

If the dispute reaches the courtroom, VAT cases belong to the administrative courts (tribunaux administratifs<\/em>, with appeal to the cours administratives d’appel<\/em>), while customs VAT disputes follow the judicial courts, as the FedEx case before the Paris Court of Appeal shows. You do not need to live in France to litigate: a French lawyer represents you, hearings rarely require your presence, and submissions are written. What you must supply from abroad is testimony-quality evidence, which means originals or certified copies, translations of foreign-language contracts by a sworn translator (traducteur asserment\u00e9<\/em>) when the administration or the court requires them, and a clear chronology of who decided what and when. Judges reading a foreign-owned company’s file ask themselves one question, which is whether this is a serious business that made an error or a mailbox used to siphon VAT. A complete file, a coherent story, and a visible French footprint, being an office, employees, real contracts, or at least a reachable representative, push you decisively into the first category.<\/p>\n

Paris and the \u00cele-de-France region add a practical layer worth knowing. The Paris tax offices handling foreign-owned companies and the customs offices around Roissy and the Paris warehouses apply the same national law, but they see more international files and ask more precise questions about representatives, intra-Community flows and platform sales. If your company is run from Paris, state the competent office correctly on every filing, keep a reachable Paris address where official letters are actually opened every week, and prepare the classic local bundle in advance: Kbis, RBE receipt, lease or domiciliation contract, representative mandate, and the last twelve VAT returns with their payment proofs. An audit that starts with this bundle on the table ends faster than one that starts with a request for the bundle.<\/p>\n

Conclusion<\/h2>\n

A French VAT number is not a formality that arrives by itself; it is the product of a complete guichet unique<\/em> file, a fast declaration of activity, the right representative where one is required, and disciplined monthly returns once identified. Invoice without inventing anything while the number is pending, use the reverse charge where the law places it, treat imports and platform sales as the high-risk zone they have become since 2021, deduct only on real invoices, claim refunds only on complete files, and answer every administration letter in writing and on time. The two court decisions in this guide draw the two borders of the territory: the Cour de cassation protects genuine economic activity and its deduction through the neutrality principle, while the Paris Court of Appeal leaves the full weight of evaded import VAT on the chain that filed false values. Run your company on the first side of that border, with an accountant who files monthly and a lawyer who reads every notice the day it arrives, and the French VAT system becomes what it is meant to be for a foreign founder: a neutral tax that flows through your company instead of sticking to it.<\/p>\n

Need a quick opinion on your case.<\/h2>\n

Get a telephone consultation within 48 hours with a lawyer of the firm. Call +33 6 46 60 58 22<\/a> or write via our contact page<\/a> with your Kbis, your latest VAT return or assessment, and the letter you received: we tell you what to file, what to pay, and what to contest.<\/p>\n","protected":false},"excerpt":{"rendered":"

Foreign owner of a French company with no VAT number yet? 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