France's tax authorities have ruled that intermediation services provided by registered press-distribution intermediaries under article 298 undecies of the French Tax Code (CGI) fall outside the mandatory electronic invoicing obligation.
France’s tax authorities issued ruling No. BOI-RES-TVA-000275 on 23 September 2026, confirming that intermediary transactions carried out by registered press-distribution intermediaries are excluded from the electronic invoicing obligation.
Published by the French Directorate General of Public Finances, the ruling applies only to intermediation services covered by article 298 undecies of the CGI.
Special VAT regime for press intermediaries
Under article 298 undecies, registered intermediaries distributing newspapers and periodicals benefit from a special VAT regime. Their intermediation services are exempt from VAT, while they keep full input VAT recovery rights. Press publishers, meanwhile, pay VAT on the total public retail price.
Why the gap arose
Under article 289 bis of the CGI, the statutory exemptions from e-invoicing cover only transactions exempted under articles 261 to 261 E of the CGI. Because article 298 undecies is not listed there, press intermediation was technically caught by the e-invoicing mandate, introduced in phases under article 26 of the Amended Finance Act for 2022.
Operational concerns
The authorities said imposing e-invoicing on these services would create significant operational burdens for the sector. Press distribution involves a structural separation between physical and financial flows among authorised distribution companies, depositaries and retailers. These services are not traditionally invoiced either; transactions are tracked through progress reports and current accounts (comptes rendus et comptes courants). The authorities noted that formal electronic invoices would bring no significant tax risk or yield.
Nature of the exclusion and conditions
The exclusion is an administrative tolerance, in place pending future legislative amendments that would extend the formal exemption. Intermediaries must maintain complete and strict documentary tracking through their existing reports and current account records.
Limits of the tolerance
The tolerance applies exclusively to article 298 undecies intermediation services. Press-distribution intermediaries and their principals must continue to comply with the mandatory e-invoicing rules for all other B2B transactions, whether they act as buyers, sellers or service providers.
