French VAT Guide: Returns, Deadlines & Fiscal Representatives for Non-EU Businesses

French VAT Guide: Returns, Deadlines & Fiscal Representatives

Published on: | Country Focus: France

Navigating the French Value Added Tax (VAT) system can be complex for non-EU businesses. France has specific requirements for foreign companies, including the mandatory appointment of a fiscal representative in many cases. This guide breaks down the French VAT return process, deadlines, and the role of fiscal representatives for non-EU businesses.

Key Takeaway: Non-EU businesses selling in France must generally appoint a fiscal representative who is jointly liable for VAT payments. Monthly VAT returns are required for most businesses, with specific deadlines based on your reporting method.

When Non-EU Businesses Need French VAT Registration

Non-EU businesses must register for French VAT in these main scenarios:

• Importing goods into France: When goods arrive in France from outside the EU
• Distance selling: Selling to French consumers exceeding €35,000 annually (2023 threshold)
• Intra-community acquisitions: Buying goods from other EU countries
• Organizing events: Hosting conferences, exhibitions or seminars in France
• Holding stock in France: Using French warehouses for storage and distribution

The Fiscal Representative Requirement

Important: Non-EU businesses generally must appoint a French fiscal representative (représentant fiscal) who is jointly liable for your VAT obligations. This representative acts as your intermediary with the French tax authorities.

Responsibilities of a Fiscal Representative

1 VAT Registration

Handles your VAT registration with the French tax authorities

2 Return Filing

Submits periodic VAT returns on your behalf

3 Payment Processing

Manages VAT payments to the French treasury

4 Compliance

Ensures compliance with French VAT regulations

Finding and Appointing a Fiscal Representative

You'll need to work with specialized firms offering fiscal representation services. These are typically:

• French accounting firms with international expertise
• International tax advisory firms
• Specialized VAT compliance companies

Costs vary based on your transaction volume and complexity, typically ranging from €1,000 to €5,000 annually plus a percentage of VAT due.

French VAT Return Process

Step 1: VAT Registration

Your fiscal representative will submit Form S0-IES (for non-EU businesses) along with required documents including:

• Certificate of incorporation
• Articles of association
• Proof of business activities
• Power of attorney for the fiscal representative

Registration typically takes 4-8 weeks. Once approved, you'll receive a French VAT number starting with "FR" followed by your SIREN number.

Step 2: Record Keeping

Maintain detailed records including:

• All sales invoices with French VAT
• Purchase invoices showing VAT paid
• Import documentation
• EC sales lists (if applicable)
• Bank statements showing VAT transactions

Step 3: VAT Return Preparation

French VAT returns (déclaration de TVA) must include:

Section	Description
VAT Collected	Total VAT charged on sales (20%, 10%, 5.5% rates)
VAT Deductible	VAT paid on business purchases and expenses
Net VAT Due	Difference between VAT collected and deductible
Exempt Transactions	Sales that are VAT exempt (exports, certain services)
Intra-Community Transactions	Sales/purchases to/from other EU countries

French VAT Deadlines

Penalty Alert: Late VAT filing incurs a 10% penalty plus 0.4% monthly interest. Late payment results in 5% immediate penalty plus 0.4% monthly interest.

Return Type	Frequency	Filing Deadline	Payment Deadline
Standard VAT Return	Monthly	19th of following month	19th of following month
Quarterly VAT Return	Quarterly (if approved)	19th of month following quarter	19th of month following quarter
Annual VAT Return	Annually (CA12K scheme)	May 2nd following year-end	Monthly/quarterly installments
EC Sales List	Monthly/Quarterly	10th of following month	N/A
Intrastat Declaration	Monthly (if thresholds exceeded)	10th of following month	N/A

Electronic Filing Requirement

All VAT returns must be filed electronically through the French tax authority's portal (impots.gouv.fr). Your fiscal representative will typically handle this process for you.

Special VAT Schemes in France

Mini-One-Stop-Shop (MOSS)

Non-EU businesses can use the MOSS scheme for digital services to EU consumers, allowing registration in a single member state.

Import VAT Deferment

Approved businesses can defer import VAT payment until their regular VAT return, improving cash flow.

CA12K Annual Scheme

For businesses with annual turnover under €236,000, allowing quarterly advance payments and an annual regularisation.

Common Pitfalls for Non-EU Businesses

• Missing fiscal representative appointment: Operating without required representation
• Incorrect VAT rates: Applying wrong French VAT rates (standard 20%, reduced 10% or 5.5%)
• Late registration: Registering after exceeding distance selling threshold
• Poor record keeping: Inadequate documentation for French tax audits
• EC sales list omissions: Forgetting to file required EU transaction reports

Conclusion

While the French VAT system presents challenges for non-EU businesses, understanding the requirements for fiscal representation, return deadlines, and compliance procedures can streamline the process. Working with an experienced fiscal representative is not just a legal requirement but a practical necessity for navigating the complexities of French VAT compliance efficiently. Proper planning and timely compliance will ensure your business operates smoothly in the French market while avoiding costly penalties.

© French VAT Guide for Non-EU Businesses. All rights reserved.

This content is designed to provide general information about French VAT requirements and should not be considered as professional tax advice. Consult with a qualified tax advisor for your specific situation.