{"id":2149744,"date":"2026-10-16T16:01:11","date_gmt":"2026-10-16T14:01:11","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/16\/foreign-company-france-invoice-french-clients-vat-representative-pe-risk-abroad\/"},"modified":"2026-10-16T16:01:11","modified_gmt":"2026-10-16T14:01:11","slug":"foreign-company-france-invoice-french-clients-vat-representative-pe-risk-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/16\/foreign-company-france-invoice-french-clients-vat-representative-pe-risk-abroad\/","title":{"rendered":"Your Foreign Company Invoices French Clients Without a French Subsidiary: VAT, Fiscal Representative and Permanent Establishment Risk"},"content":{"rendered":"

You run a company registered in Delaware, London, Dubai or Singapore. You have no office in France, no French company, and no French bank account. Yet French clients pay your invoices, sometimes every month, sometimes for six-figure amounts. One day your accountant, your client, or a letter from the French tax office asks the question you should have asked first: do those invoices owe something to France? The answer comes in two layers that foreigners constantly confuse. The first layer is value added tax (TVA, taxe sur la valeur ajout\u00e9e): France may claim VAT on your services even though your company is foreign, and the mechanism that collects it is often your own client. The second layer is corporate income tax (IS, imp\u00f4t sur les soci\u00e9t\u00e9s): if your activity in France crosses a legal line called permanent establishment (\u00e9tablissement stable), France taxes the profit itself, not just the invoice. This guide explains both layers in the order a careful founder should examine them, with the exact French legal texts and two court decisions that show where the line sits. If you have not yet created any French structure, start with our complete setup guide for foreign founders: bank account, Kbis, VAT and first hire<\/a>, which describes the Kbis (the official company identity certificate issued by the commercial court registry, the greffe) and the standard registration path; this article covers the opposite situation, where you invoice France without any French vehicle at all.<\/p>\n

I. Your invoices can owe French VAT even though your company is foreign<\/h2>\n

French VAT does not care where your company is registered. It cares where the service is deemed supplied and who the customer is. A surprising number of foreign founders discover this backwards: they invoice a Paris client with zero VAT because “we are not a French company”, the client stays silent, and two years later the tax office asks why no French VAT was ever declared on services consumed in France. The rules below decide, invoice by invoice, whether French VAT applies and, crucially, who must pay it to the Treasury. Get this wrong and either you absorb 20 percent you never priced in, or your client does and blames you.<\/p>\n

A. Where your services are taxed and who actually pays the French VAT<\/h3>\n

The starting point is the place-of-supply rule. Article 259 of the General Tax Code (CGI, Code g\u00e9n\u00e9ral des imp\u00f4ts) states: “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”. The article is published on L\u00e9gifrance, article 259 of the General Tax Code<\/a>. In plain English: when your client is a business customer (an assujetti, a VAT-taxable person) established in France, the service is deemed supplied in France. That is the B2B rule, and it covers consulting, software development, design, marketing, legal and accounting support, and most services a foreign company sells to French firms. The mirror rule in the same article covers sales to private individuals: when the customer is not a taxable person, the service is located in France if you, the supplier, are established in France. Since you are not, most B2C services supplied from abroad to French consumers escape French VAT under this article, with important exceptions for digital services, transport, and services physically performed in France, which follow special place rules you must check operation by operation.<\/p>\n

Once a B2B service is located in France, the next question is who pays the VAT, and here French law relieves the foreign supplier in the standard case. Article 283 of the General Tax Code provides: “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.” The text is available on L\u00e9gifrance, article 283 of the General Tax Code<\/a>. This is the reverse charge (autoliquidation): your French business client declares the French VAT on its own return and deducts it at the same time, so the operation is cash-neutral for a client entitled to full deduction, and you invoice without French VAT. The same article extends the mechanism to supplies of goods and services covered by article 259 A performed by a supplier 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.” Three practical consequences follow. First, always collect and verify your French client’s VAT identification number before invoicing; without it, the reverse charge has no debtor and the risk falls back on you. Second, write the exact legal reference on the invoice, typically Autoliquidation under article 283-2 of the CGI, VAT due by the customer,, because an invoice with neither VAT nor a stated legal basis looks like an omission in an audit. Third, confirm the client really acts as a taxable person for that purchase: a French holding, association, or public body that is not a taxable person for the activity concerned cannot self-assess, and the B2B rule may not even locate the service in France, which changes the whole analysis.<\/p>\n

Three common situations break this comfortable pattern, and each has trapped foreign suppliers. The first is the private customer. If you sell coaching, training, SaaS subscriptions, or creative work directly to French consumers from outside France, the B2B reverse charge does not exist, and either French VAT genuinely does not apply under article 259 or a special rule (digital services, cultural or sporting events performed in France, short-term transport hire) pulls the service back into French VAT with you as the debtor. Never assume consumer sales are safe; qualify each product line. The second is goods. Storing stock in a French warehouse, using Amazon FBA in France, or delivering goods located in France at the time of sale makes you a supplier of domestic French deliveries, which are taxable in France with no reverse charge available to save you: you must register and charge French VAT. The third is the subcontracting chain in construction and related sectors, where domestic reverse charge rules between French-established parties interact with your foreign status in ways that depend on whether you are deemed established in France for VAT purposes, a concept distinct from the corporate-tax establishment discussed in Part II. A company can be established for VAT (a fixed establishment, \u00e9tablissement stable TVA, meaning human and technical resources permanently present) without being a permanent establishment for corporate tax, and vice versa. Keep the two analyses separate, document each, and never let a conclusion on one silently decide the other.<\/p>\n

B. Getting a French VAT number and filing returns from abroad<\/h3>\n

Whenever French VAT is due by you rather than by your client, you need a French VAT identification number and a filing channel, office or no office. French law is blunt about the starting obligation. Article 286 of the General Tax Code requires every person liable to VAT: “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.” See L\u00e9gifrance, article 286 of the General Tax Code<\/a>. For a foreign company, that declaration is the registration request filed with the tax office for non-residents (SIE des non-r\u00e9sidents, service des imp\u00f4ts des entreprises, based in Noisy-le-Grand near Paris), which issues the individual VAT number. Article 286 ter of the General Tax Code states: “Est identifi\u00e9 par un num\u00e9ro individuel : 1\u00b0 Tout assujetti qui effectue des livraisons de biens ou des prestations de services lui ouvrant droit \u00e0 d\u00e9duction”. The article is on L\u00e9gifrance, article 286 ter of the General Tax Code<\/a>. That FR-prefixed number goes on every invoice you issue for French operations, and your clients will check it in the European VIES database before applying any reverse charge, so a wrong or missing number freezes payments in practice.<\/p>\n

The registration path then splits between EU and non-EU companies, and the split is expensive to misunderstand. A company established in another EU member state registers directly with the SIE des non-r\u00e9sidents, files the French VAT returns itself (usually electronically, through a French-speaking accountant in practice), and reclaims French input VAT through the same channel. A company established outside the European Union faces an additional gatekeeper. Article 289 A of the General Tax Code provides: “Lorsqu’une personne non \u00e9tablie dans l’Union europ\u00e9enne est redevable de la taxe sur la valeur ajout\u00e9e ou doit accomplir des obligations d\u00e9claratives, elle est tenue de faire accr\u00e9diter aupr\u00e8s du service des imp\u00f4ts un repr\u00e9sentant assujetti \u00e9tabli en France qui s’engage \u00e0 remplir les formalit\u00e9s incombant \u00e0 cette personne et, en cas d’op\u00e9rations imposables, \u00e0 acquitter la taxe \u00e0 sa place.” The full article is on L\u00e9gifrance, article 289 A of the General Tax Code<\/a>. This fiscal representative (repr\u00e9sentant fiscal) is a French-established taxable person, typically a specialised firm, accredited by the tax office, who files and pays in your place and is jointly on the hook if the VAT goes unpaid, which is why representatives demand guarantees, monthly fees, and clean documentation before accepting you. The same article carves out exemptions, notably for persons established in a non-EU state with which France has a mutual-assistance instrument of comparable scope to the EU recovery and cooperation framework, and since that list evolves with treaties, a British, Swiss, Norwegian, or American company must verify its current status with the SIE instead of assuming it needs, or escapes, a representative. Note the sanction built into the article: without an accredited representative where one is required, the VAT and any penalties are claimed from the customer, which gives your French clients a direct reason to demand proof of your representative before paying a large invoice.<\/p>\n

Once registered, the ongoing discipline is the same as for a French company, with distance as an aggravating factor. Article 287 of the General Tax Code states: “Tout redevable de la taxe sur la valeur ajout\u00e9e identifi\u00e9 conform\u00e9ment aux dispositions combin\u00e9es des articles 286 ter et 286 ter A est tenu de remettre au service des imp\u00f4ts dont il d\u00e9pend et dans le d\u00e9lai fix\u00e9 par arr\u00eat\u00e9 une d\u00e9claration conforme au mod\u00e8le prescrit par l’administration.” See L\u00e9gifrance, article 287 of the General Tax Code<\/a>. Under the standard actual-payment regime (r\u00e9gime r\u00e9el normal), the same article continues: “Les redevables soumis au r\u00e9gime r\u00e9el normal d’imposition d\u00e9posent mensuellement la d\u00e9claration”, the well-known CA3 return, with quarterly filing tolerated when the annual VAT due stays below 4,000 euros. From abroad, three operational points matter most. First, calendar discipline: French VAT returns are filed and paid electronically within weeks of the period end, and a founder in another time zone who discovers the deadline from a penalty notice has already lost money. Second, invoice compliance: French invoices must show your FR VAT number, the client’s valid VAT number for reverse charge, the legal basis for any VAT exemption or reverse charge, and sequential numbering with no gaps; keep copies for at least six years, because a VAT audit of a non-established company typically starts with a demand for the full invoice file. Third, appoint a French accountant or tax agent even when the law does not force you to: the SIE des non-r\u00e9sidents corresponds in French, applies French procedural deadlines, and will not wait for translations, so a local professional is not a luxury but the practical condition of staying registered without surprises. The official guidance published by the tax administration in the BOFiP (Bulletin officiel des finances publiques) details each of these steps; always check the current BOFiP pages on the impots.gouv.fr portal before filing, because thresholds, forms, and contact details change more often than the Code itself.<\/p>\n

II. When France decides you are really doing business here: the permanent establishment risk<\/h2>\n

VAT is only the first layer. The second layer is heavier: France may consider that your foreign company carries on a business in France through a permanent establishment, and then it taxes the corresponding profit with French corporate income tax, plus penalties and interest, even though the company itself remains registered abroad. Founders often discover this layer during a tax audit, when the administration points at a Paris-based salesperson, a French subsidiary that “helps” a little too much, or an executive who moved to France but kept signing for the foreign company. The amounts at stake dwarf a VAT adjustment, because corporate tax applies to margins accumulated over several years. The good news is that the line is drawn by published court decisions you can read and apply to your own facts before the administration does it for you.<\/p>\n

A. The two doors through which a foreign company becomes taxable in France<\/h3>\n

The domestic anchor is short and strict. Article 209 of the General Tax Code provides that profits liable to corporate income tax are determined “en tenant compte uniquement des b\u00e9n\u00e9fices r\u00e9alis\u00e9s dans les entreprises exploit\u00e9es en France”, as well as profits “dont l’imposition est attribu\u00e9e \u00e0 la France par une convention internationale relative aux doubles impositions”. The article is published on L\u00e9gifrance, article 209 of the General Tax Code<\/a>. Two elements therefore combine: an enterprise operated in France, and, where a tax treaty applies, an attribution of taxing rights to France under that treaty. Article 206 of the General Tax Code completes the picture by listing who is liable in the first place: “sont passibles de l’imp\u00f4t sur les soci\u00e9t\u00e9s, quel que soit leur objet, les soci\u00e9t\u00e9s anonymes, les soci\u00e9t\u00e9s en commandite par actions, les soci\u00e9t\u00e9s \u00e0 responsabilit\u00e9 limit\u00e9e”, alongside other profit-making legal persons. See L\u00e9gifrance, article 206 of the General Tax Code<\/a>. A foreign company of a comparable type falls within this scope as soon as it operates an enterprise in France; no French registration is required for the tax to bite, which is exactly why companies that deliberately avoided creating a French subsidiary are still reassessed. Where a treaty exists, and France has treaties with most trading partners, the treaty defines the establishment that allows France to tax, and the treaty prevails over domestic law in the taxpayer’s favour.<\/p>\n

Treaties open two doors, and the administration only needs one. The first door is the fixed place of business: an office, a workshop, a building site beyond the treaty time threshold, or any fixed installation through which the foreign company’s business is wholly or partly carried on. A Paris office with your logo, French employees working daily from a coworking space on your business, or stock held permanently in a French warehouse all point through this door. The second door is the dependent agent: a person in France, who may be an individual or a company including your own French subsidiary, who habitually exercises powers allowing it to bind the foreign company in commercial relationships relating to its own operations. The Conseil d’\u00c9tat gave this door its modern French formulation in its decision of 11 December 2020, no. 420174, Conversant International Ltd, holding that such powers are exercised by “une soci\u00e9t\u00e9 fran\u00e7aise qui, de mani\u00e8re habituelle, m\u00eame si elle ne conclut pas formellement de contrats au nom de la soci\u00e9t\u00e9 irlandaise, d\u00e9cide de transactions que la soci\u00e9t\u00e9 irlandaise se borne \u00e0 ent\u00e9riner et qui, ainsi ent\u00e9rin\u00e9es, l’engagent.” The full decision is published on L\u00e9gifrance, Conseil d’\u00c9tat, 11 December 2020, no. 420174<\/a>. In that case, the French sister company chose the advertisers, did all the work to conclude the contracts, and the Irish company merely validated them with what the Court treated as an automatic signature: the French company was the Irish company’s permanent establishment, and years of profit became taxable in France. Read that sentence against your own organisation. If your French team negotiates everything and the foreign head office only rubber-stamps, you are on the Conversant side of the line.<\/p>\n

The counterweight is the Google decision, which shows what a structure that survives looks like. The Paris administrative court of appeal examined the relationship between Google Ireland Limited in Dublin and the French company Google France, and concluded: “Il r\u00e9sulte de tout ce qui pr\u00e9c\u00e8de que la soci\u00e9t\u00e9 Google Ireland Limited ne dispose pas en France d’un \u00e9tablissement stable, au sens de la convention franco-irlandaise”. The judgment, which rejected the minister’s appeal seeking to reinstate the reassessed corporate tax for 2005 to 2010, is published on L\u00e9gifrance, Paris administrative court of appeal, 25 April 2019, no. 17PA03067<\/a>. The decisive facts were contractual and operational at once: the service agreement expressly stated that the French company “n’a pas le pouvoir d’engager la Soci\u00e9t\u00e9 [Google Ireland Limited], d’agir comme mandataire ou repr\u00e9sentant autoris\u00e9”, could not negotiate contracts or accept orders on its behalf, and the court verified that reality matched the paper, with the actual conclusion of advertising contracts remaining in Dublin. The lesson for founders is not that a well-drafted contract alone saves you; the Conversant team also had contracts. The lesson is alignment: the paper must deny the power to bind, the reporting lines must keep pricing and acceptance decisions genuinely abroad, and the email record must show French staff supporting rather than deciding. Auditors read emails before they read contracts, so assume every message in which a Paris employee promises a client “we will sign” will be quoted back to you.<\/p>\n

Five red flags should trigger an immediate review while you still control the timeline. First, a person in France who negotiates prices, grants discounts, or says yes to clients while the foreign company only signs afterwards. Second, French employees whose bonuses depend on contracts signed, whatever their job titles say. Third, a French subsidiary whose only real activity is selling the foreign company’s offering, with shared management and shared tools. Fourth, a founder or executive who moved to France and continues to run the foreign company from a French home, because the place of effective management can relocate tax residence questions on top of the establishment analysis. Fifth, French clients who all believe they contract with “your Paris team” while your invoices claim a purely foreign supplier. None of these flags is a verdict by itself, and the Google case proves that a French support presence can be lawful, but each flag shifts the burden of proof in the auditor’s mind, and several together make reassessment likely. Map them honestly now, when restructuring is still a business decision, rather than later, when it becomes a defence argument.<\/p>\n

B. Putting your French activity back on safe rails from abroad<\/h3>\n

Once the risk is mapped, the cleanup follows a strict order: stop the bleeding, regularise the past, then choose the vehicle for the future. Stopping the bleeding means rewriting the facts before rewriting the paper. Move real decision-making abroad or formalise it there: pricing grids approved in writing by the foreign board, acceptance of orders on foreign systems, contracts signed by foreign officers after genuine review, and French job descriptions, bonus schemes, and email signatures that describe support, prospecting, and after-sales rather than sales authority. Then align the contracts with the new reality: intercompany service agreements that pay the French entity a verifiable arm’s-length fee for what it actually does, general terms that name the foreign contracting party, and powers of attorney that withhold rather than grant signing authority. Do this with your accountant and lawyer together, because a transfer-pricing agreement that contradicts the VAT position, or an employment bonus that contradicts the agency analysis, hands the auditor the contradiction it needs. Keep every version: reformed documents prove the current state, while the history log shows good faith if past years are questioned.<\/p>\n

Regularising the past is the step founders resist and auditors reward. If French VAT should have been charged or reverse-charged on past invoices, file the missing registrations and returns spontaneously through the SIE des non-r\u00e9sidents or your fiscal representative before any audit notice arrives; spontaneous correction does not erase interest for late payment, but it typically halves the penalty exposure compared with a reassessment and demonstrates the good faith that penalty relief procedures require. If a permanent establishment may have existed, quantify the profit attributable to France year by year with a documented method, file the corresponding corporate returns, and prepare the file as if the auditor were already appointed: contracts, organisation charts, travel records, board minutes showing where decisions were taken, and the pricing method for dealings between the head office and the French presence. Where the analysis is genuinely uncertain, a formal tax ruling request (rescrit fiscal) to the French administration locks in its position on your described facts and protects you against penalties as long as you implement exactly what you described; it is slow, often several months, but it converts an endless worry into a written answer. Never backdate documents, never create board minutes for meetings that never happened, and never instruct staff to tell a single story: in a criminal-tax context, which large hidden establishments can reach, fabricated evidence destroys the good faith that keeps most cases within financial penalties.<\/p>\n

The final choice is structural, and it is where many foreign founders realise that the improvised setup costs more than the clean one. If France is a lasting market, three vehicles exist. A liaison office (bureau de liaison) does market research and promotion but cannot conclude business; it is cheap and safe only while it stays strictly preparatory, and the moment its staff starts negotiating, it becomes a permanent establishment with no return filed, the worst of both worlds. A branch (succursale) is a direct extension of the foreign company, registered with the commercial court registry (greffe du tribunal de commerce) and published in the official bulletin of civil and commercial announcements (BODACC, Bulletin officiel des annonces civiles et commerciales); it has no separate legal personality, so the foreign parent remains fully liable, but it gives clients a Kbis-style registration, a visible French address, and a straightforward filing channel for VAT and payroll. A subsidiary, usually a SAS for foreign founders, is a separate French person with its own liability shield, its own Kbis, and the familiar dividend and salary routes for taking money out later, at the cost of full French accounting and governance. The branch-versus-subsidiary comparison deserves its own study for your figures, but the decision rule is simple: a branch suits a controlled commercial outpost you may close, a subsidiary suits a business you intend to grow, sell, or staff heavily. Either way, register before the administration registers you: a voluntary filing chooses the vehicle, while a reassessment imposes the tax without any of the vehicle’s advantages.<\/p>\n

Conclusion<\/h2>\n

Invoicing French clients without a French company is lawful and common, but it is not tax-neutral. On the VAT layer, remember the sequence: locate each service under article 259, let the French business client self-assess under article 283 whenever the conditions are met, and register with a French VAT number, through a fiscal representative if you are outside the EU, as soon as the VAT becomes yours to declare and pay. On the corporate-tax layer, remember the two doors: no fixed French installation through which your business runs, and no French person who habitually decides transactions your company merely endorses, in the exact sense the Conversant decision gives those words, with the Google decision as your template for a support presence that stays on the safe side. The founders who pay the least tax over time are not those who hide from the French administration the longest; they are those who qualify each invoice, document where each decision is taken, regularise spontaneously when the past is wrong, and give a durable French activity the registered vehicle it deserves. France rewards declared businesses with legal certainty, deductible costs, and recoverable VAT; it punishes discovered ones with reassessments, penalties, and years of litigation. Choose the first path while the choice is still yours.<\/p>\n","protected":false},"excerpt":{"rendered":"

No French office and French clients on your invoices? 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