You run your business from London, New York, Dubai or Singapore, and France has become too large a market to ignore. Pallets leave a warehouse for Lyon, your online store ships dozens of parcels a week to Paris, or a French group pays your monthly invoices for software, design or consulting. Then a French customer asks for an invoice with French value added tax (VAT), your logistics provider mentions a French VAT number, or an email from the French tax administration arrives asking why you have never filed anything in France. The uncomfortable question follows: should your foreign company have registered for VAT in France months ago, and what does the delay cost?<\/p>\n
This guide answers that question for a foreign founder or finance team with no French establishment. It explains when French VAT applies to goods stored or delivered in France, when services supplied to French customers are taxed in France and who must pay the tax, how the European One-Stop Shop (OSS, the EU portal that lets businesses declare distance sales in several Member States through a single return) fits in and where it stops, and how to register, invoice and file from abroad. It closes with what late registration really costs \u2014 back tax, interest and penalties \u2014 and how to regularise and challenge an assessment. French legal terms are translated throughout, and every decisive rule is quoted from its official source so your team can act on verified law rather than rumour.<\/p>\n
French VAT starts with a simple principle stated in Article 256 of the CGI (Code g\u00e9n\u00e9ral des imp\u00f4ts, the French Tax Code): “Sont soumises \u00e0 la taxe sur la valeur ajout\u00e9e les livraisons de biens et les prestations de services effectu\u00e9es \u00e0 titre on\u00e9reux par un assujetti agissant en tant que tel.”<\/a> In plain English, supplies of goods and services made for consideration by a taxable person acting as such fall within VAT. A foreign company selling into France is, in principle, no exception: once the transaction is located in France under French territorial rules, French VAT applies and somebody must account for it.<\/p>\n For goods, the place of supply is where the goods are. Article 258 of the CGI provides that “Le lieu de livraison de biens meubles corporels est r\u00e9put\u00e9 se situer en France lorsque le bien se trouve en France”<\/a> at the time of dispatch, transport, installation or handing over, depending on the case. Three everyday situations for foreign businesses follow directly from this. First, goods you hold in a French warehouse \u2014 your own stock, an Amazon fulfilment centre in France, a third-party logistics platform near Lyon \u2014 and deliver to French customers are domestic French supplies. Second, goods you install or assemble in France are French supplies. Third, goods shipped from another European Union country to private French customers are intra-Community distance sales located in France as the Member State of arrival. In each case the transaction is a French transaction for VAT purposes even though your company is managed from abroad and has no French office, no French trade registration and no Kbis (the official certificate issued by the greffe, the registry of the commercial court, proving a French company exists).<\/p>\n The practical consequence is that many foreign sellers need a French VAT identification number long before they incorporate anything in France. A VAT number is not the same as a company registration. France identifies each business with a SIREN (a nine-digit national business identifier), and the intra-Community VAT number of a French operator is built as FR plus two check digits plus the SIREN. A foreign company without a French establishment can obtain a French VAT number purely for tax purposes, without becoming a French company and without a Kbis, by registering with the SIEE (Service des imp\u00f4ts des entreprises \u00e9trang\u00e8res, the dedicated tax office for foreign companies, located at Noisy-le-Grand in the Paris region). The official impots.gouv.fr guidance for foreign businesses operating in France without an establishment describes exactly this route, and the BOFiP (Bulletin officiel des finances publiques, the administration’s published tax doctrine) sets out how companies established outside the European Union appoint a tax representative and complete the registration. Registration for VAT therefore does not require a French subsidiary, a branch entered on the trade register, or a French bank account \u2014 it is a tax identification step, and it should be taken as soon as taxable operations in France begin.<\/p>\n Two reliefs are often misunderstood and deserve precise wording. Exports out of the European Union are exempt: Article 262 of the CGI states that “Sont exon\u00e9r\u00e9es de la taxe sur la valeur ajout\u00e9e : 1\u00b0 les livraisons de biens exp\u00e9di\u00e9s ou transport\u00e9s par le vendeur ou pour son compte, en dehors de la Communaut\u00e9 europ\u00e9enne ainsi que les prestations de services directement li\u00e9es \u00e0 l’exportation”<\/a>. That exemption covers goods leaving the Union, not goods circulating inside France, so stocking a French warehouse for French customers never qualifies. And the OSS simplification for distance sales does not remove the need to think about registration: the Union OSS scheme lets a business established in one Member State declare distance sales to consumers in other Member States through a single quarterly return, but it only covers business-to-consumer supplies of goods and certain services up to its defined scope, it requires registration in the Member State of identification, and it never covers domestic French supplies from French stock, goods installed in France, or supplies that French law places under mandatory reverse charge or a fiscal representative. A practical rule for founders is therefore to map every physical flow separately: where is the stock, where does transport end, who is the customer, and does any French warehouse, installation or over-the-threshold distance selling create a French supply that OSS cannot absorb? Our broader walkthrough for newcomers, Setting Up a Company in France as a Foreign Founder: Bank Account, Kbis, VAT and Your First Hire<\/a>, places this VAT analysis inside the full set-up sequence, from the bank account and the Kbis to the first hire, so the VAT decision is never taken in isolation.<\/p>\n Distance selling thresholds deserve a final warning because the old national thresholds are gone. Since the 2021 European reform there is a single Union-wide threshold of 10,000 euros for distance sales of goods and certain electronic services to consumers: below it, a business established in one Member State may tax those sales at home; above it, the sales are taxed in the Member State of the customer and must be declared there directly or through the OSS. For a British, American or Gulf-based seller this means the first euros of sales to French consumers can already be French-taxed transactions once the goods arrive in France, and the question is never whether the amounts feel small but where the law locates them. Keep transport proofs, warehouse receipts and platform reports from the first shipment, because the date the goods started sitting in France, not the date you first heard about French VAT, will set the starting point of any later assessment.<\/p>\n Services follow a different compass from goods, and most disputes involving foreign providers turn on two articles read together. Article 259 of the CGI fixes the place of supply: “Le lieu des prestations de services est situ\u00e9 en France : 1\u00b0 Lorsque le preneur est un assujetti agissant en tant que tel et qu’il a en France : a) Le si\u00e8ge de son activit\u00e9 \u00e9conomique, sauf lorsqu’il dispose d’un \u00e9tablissement stable non situ\u00e9 en France auquel les services sont fournis”<\/a>. In ordinary language, when your customer is a French business acting as such \u2014 a French SAS (soci\u00e9t\u00e9 par actions simplifi\u00e9e, the flexible French limited company), a SARL (soci\u00e9t\u00e9 \u00e0 responsabilit\u00e9 limit\u00e9e, the closed French limited company) or a French branch of a foreign group \u2014 the service is located in France. When your customer is a French private individual, the default is the opposite: the service is located where you, the provider, are established, except for a closed list of services that French law expressly relocates to France, such as services connected with immovable property in France, passenger transport performed in France, access to cultural or sporting events taking place in France, restaurant services supplied in France and short-term hiring of means of transport put at the customer’s disposal in France.<\/p>\n The second article decides who pays. Article 283 of the CGI states that where such a supply is made by a trader established outside France, “la taxe est acquitt\u00e9e par l’acqu\u00e9reur, le destinataire ou le preneur qui agit en tant qu’assujetti et qui dispose d’un num\u00e9ro d’identification \u00e0 la taxe sur la valeur ajout\u00e9e en France”<\/a>, and its second paragraph, constantly applied by the courts, adds that “Lorsque les prestations mentionn\u00e9es au 1\u00b0 de l’article 259 sont fournies par un assujetti qui n’est pas \u00e9tabli en France, la taxe doit \u00eatre acquitt\u00e9e par le preneur”<\/a>. This is the reverse charge (autoliquidation): for business-to-business services located in France but supplied by a provider with no French establishment, the French business customer accounts for the VAT on its own return, and the foreign provider invoices without French VAT while showing both parties’ VAT numbers and a reverse-charge note. The mechanism explains why a foreign consultancy invoicing a Paris group from abroad usually needs no French VAT number at all, provided the client is genuinely a taxable person with a French VAT number and the invoice trail proves it. Ask every new French business client for its VAT number, check it on the European VIES database before the first invoice, and keep the verification \u2014 an expired or invalid number at the invoice date destroys the reverse charge and can push the liability back to you.<\/p>\n The borderline that generates litigation is the stable establishment. A foreign provider that merely emails deliverables from abroad is not established in France; a foreign provider with French-based staff, equipment or premises through which the services are materially performed may be. The Conseil d’\u00c9tat (the supreme court for administrative and tax disputes) held on 15 June 2023, decision number 465719, that “Doit \u00eatre regard\u00e9 comme tel le prestataire qui a en France un \u00e9tablissement stable depuis lequel les prestations sont fournies et qui pr\u00e9sente un degr\u00e9 suffisant de permanence et une structure apte, du point de vue de l’\u00e9quipement humain et technique, \u00e0 rendre possibles, de mani\u00e8re autonome, les prestations de services consid\u00e9r\u00e9es.”<\/a> In that case the court upheld a VAT assessment against a company whose services were treated as supplied through a French stable establishment, without even asking whether allocating the services to the foreign head office would have been more rational. Founders should read this as a factual test, not a formal one: a Paris coworking desk used two days a month changes nothing, but a team of engineers, salespeople or technicians working from French premises on the very services invoiced can make your company established in France for those services, switching off the reverse charge and switching on a registration and collection duty.<\/p>\n Intragroup services add a second trap that foreign groups discover during audits. The Paris administrative court of appeal held on 28 June 2022, case number 21PA01595, that “Pour l’application de ces dispositions, le preneur s’entend de la personne qui est le b\u00e9n\u00e9ficiaire effectif de la prestation de service.”<\/a> Management fees, brand royalties and shared-service recharges billed by a British, Dutch or American parent to the French subsidiary must therefore be examined for who really benefits: where the French company is the effective recipient, it owes reverse-charge VAT on the recharge even if the contract routes the invoice through another entity, and the administration regularly reassesses groups that forgot this self-assessed VAT while deducting the corresponding input tax elsewhere. Document each recharge with a service agreement, time records or cost keys, and a transfer-pricing file consistent with the VAT position, because the corporate-tax and VAT analyses of the same fee must tell the same story. The same discipline applies to seconded staff, software licences billed per French user and marketing costs recharged to the French market \u2014 each flow gets its own place-of-supply analysis, and none of them is saved by the argument that the group already pays tax somewhere else.<\/p>\n Registration is an administrative declaration, not a negotiation, and the clock starts early. Article 286 of the CGI requires that “Dans les quinze jours du commencement de ses op\u00e9rations, souscrire au bureau d\u00e9sign\u00e9 par un arr\u00eat\u00e9 une d\u00e9claration conforme au mod\u00e8le fourni par l’administration.”<\/a> A foreign company with no French establishment files with the SIEE, the foreign-companies tax office, while a company that already has a French establishment files with the SIE (Service des imp\u00f4ts des entreprises, the corporate tax office) of the place of that establishment. In practice the file contains the foreign certificate of incorporation with a sworn French translation, proof of the foreign registered office, the identity and powers of the legal representative, a description of the planned French operations with the expected start date, the identity of the French fiscal representative where one is mandatory \u2014 broadly, companies established outside the European Union \u2014 and, for distance sellers, the platform and warehouse details that locate the supplies in France. The administration then issues the French VAT number, and the official BOFiP doctrine on registration of businesses established outside the Union details the representative’s joint liability and the supporting documents the SIEE expects. Allow several weeks between filing and issuance, and do not start charging French VAT or filing French returns on a number you have merely applied for: invoices must show the number once allocated, and any pre-registration French VAT collected in error has to be corrected rather than quietly kept.<\/p>\n Timing mistakes are the most expensive part of this topic, so set the calendar before the first French invoice. The fifteen-day declaration period runs from the start of operations, meaning the first storage of goods in France, the first delivery from French stock, the first installation, or the first service located in France \u2014 not from the first time a customer asks about VAT. Businesses that discover the duty late sometimes hope the OSS will backdate everything: it will not. The OSS covers eligible periods through its own registration in the Member State of identification and cannot cure domestic French supplies, periods before OSS registration, or supplies excluded from the scheme. Where a fiscal representative is required, appointing one late does not erase the earlier period either; it only secures the future. The clean sequence is therefore to freeze new French-taxable flows where possible, file the SIEE declaration immediately with a candid start date, ask the representative or adviser to quantify the exposure for the open years, and prepare corrective invoices and returns before the administration opens the discussion. A file opened voluntarily, with numbers and money attached, is treated very differently from the same file opened by an audit notice.<\/p>\n A short Paris and \u00cele-de-France note helps foreign teams organise themselves. The SIEE sits at Noisy-le-Grand, in the Seine-Saint-Denis department east of Paris, and it handles foreign companies without a French establishment nationwide, so correspondence, powers of attorney and translations flow there rather than to a Paris arrondissement office. If your project later gains a real French presence \u2014 a Paris office with staff, a warehouse in the Val-d’Oise, a store in Hauts-de-Seine \u2014 the competent office for ongoing VAT becomes the SIE of that establishment, and the file migrates. Disputes follow the administrative track: an initial claim (r\u00e9clamation) to the tax office, then the tribunal administratif (the administrative court), with Paris-region cases generally going to the Montreuil or Paris administrative courts depending on the office, and appeals to the Paris administrative court of appeal. Keep a single French-language contact file with the SIEE correspondence, the representative agreement, the mandate for the adviser, and a table of every French flow by month: auditors ask for exactly this, and producing it in days rather than months changes the tone of the control. Companies that already run a French subsidiary alongside the foreign principal should keep the two files strictly separate \u2014 the subsidiary files with its own SIE under its own SIREN, while the foreign head office, if it makes its own French-taxable supplies, holds its own SIEE number \u2014 because mixing the two numbers on invoices is one of the fastest routes to a reassessment.<\/p>\n Identification also determines what appears on your invoices and contracts. Once registered, show the French VAT number on every document relating to French operations, align the invoicing entity with the registered entity \u2014 the foreign company with its SIEE number, not the future French subsidiary, not the parent with a foreign-only number \u2014 and update marketplaces, payment providers and the French-language general terms so the VAT clauses point to the right entity. Where the reverse charge applies to your purchases from French suppliers or to services you supply to French businesses, the invoice must carry the words autoliquidation and both VAT numbers, because the customer’s right to deduct depends on your paperwork as much as on its own.<\/p>\nB. Services supplied to French clients: where the service is taxed in France and who must pay the tax<\/h3>\n
II. How to register, invoice and fix late registration from abroad without coming to France<\/h2>\n
A. Getting your French VAT number from abroad: the foreign-companies office, forms, timing and Paris specifics<\/h3>\n
B. Invoicing, filing and paying French VAT, then dealing with the past: costs, voluntary correction and how to challenge<\/h3>\n