France has deferred the transfer of VAT provisions from the General Tax Code (CGI) to the Code des impositions sur les biens et services (CIBS) until 1 January 2027, while introducing technical clarifications to the recodified framework. The ordinance preserves existing VAT rules and administrative obligations, giving businesses additional time to prepare for the transition without materially changing the substance of the regime.
France has postponed the transfer of Value Added Tax (VAT) provisions from the General Tax Code (CGI) to the Code des impositions sur les biens et services (CIBS) until 1 January 2027 under Ordinance No. 2026-671 of 27 July 2026, published in the Official Journal on 28 July. The ordinance amends Ordinance No. 2025-1247 of 17 December 2025, which had scheduled the recodification to take effect on 1 September 2026.
Until 31 December 2026, the VAT provisions and references contained in the General Tax Code (CGI), including those governing real estate VAT and VAT on rents, will continue to apply. From 1 January 2027, they will be replaced by the corresponding provisions in the Code des impositions sur les biens et services (CIBS). The report accompanying the ordinance does not provide any exception for real estate VAT.
Clarifications to the VAT framework
In addition to postponing the implementation date, the ordinance refines the recodified VAT framework by clarifying definitions and operational rules. It updates the treatment of taxable transactions, intra-European deliveries, imports, provision of services and the place of operation. The ordinance also confirms that the taxable base generally consists of the total consideration received by the supplier, including monetary and in-kind payments, while setting out specific rules for single-use and multi-use vouchers and for imported goods based on customs value.
Liability, deductions and sector-specific rules
The ordinance maintains existing provisions on VAT rates, exemptions and liability. It preserves reduced, very reduced, zero and special VAT rates for eligible goods and services, as well as exemptions covering intra-European deliveries, exports, specified humanitarian aid and certain imported personal belongings. It also confirms reverse charge provisions, joint liability rules for certain travail à façon arrangements, proportional (prorata) VAT deduction methods and sector-specific regimes for agriculture, second-hand goods, investment gold, travel operators and copyright royalties.
Administrative obligations remain
The updated framework also maintains VAT administrative requirements, including invoicing, record-keeping and reporting obligations. Taxable persons must continue to issue invoices containing mandatory VAT information, maintain registers for intra-European movements of goods and specified transactions, and submit data required by the tax authorities to verify VAT liability. The postponement provides businesses with additional time to prepare for the migration of VAT legislation to the CIBS, while leaving the substance of the recodified framework largely intact ahead of its application from 1 January 2027.
