France’s tax authority has updated its guidance on the international agent regime for VAT after a public consultation, clarifying eligibility, covered transactions and agent obligations.
France’s Tax authority, the Directorate General of Public Finance (DGFiP), published updated guidance on 14 October 2026 on the international agent regime for value added tax (VAT), following a public consultation held earlier this year.
Under Article 289 A bis of the French General Tax Code (CGI) and Article 95 ter of Annex III to the code, in force since 1 January 2025, non-established, non-VAT-registered businesses can appoint an established French agent to handle their VAT filings for certain transactions. They can thus avoid registering for French VAT or appointing a fiscal representative.
Eligibility and scope
The regime is open to taxable persons, from EU member states and third countries alike, that are neither established nor VAT-identified in France. Eligibility ends once a business receives a standard French VAT number.
It covers only operations on goods entrusted to the agent where French VAT is fully deductible, exempt or suspended. These include:
- imports followed by exportation outside the EU, or by a domestic sale, rental or installation subject to reverse-charge VAT by a French VAT-identified customer;
- export sales of goods purchased in France; and
- exits from customs or tax suspensive regimes followed immediately by an export or an exempt supply under Article 262 of the CGI.
Intra-Community acquisitions and supplies, and domestic sales to non-taxable persons or buyers without a French VAT number, are excluded. A business that carries out an ineligible transaction must register for French VAT and/or appoint a permanent fiscal representative.
Agent requirements
An agent must have been established and VAT-identified in France for at least one year, with VAT returns filed in its own name for the same period. It must have no serious or repeated tax infringements or commercial court sanctions in the past three years, and must hold physical custody of the goods under a specific contract.
Mandate, filing and liability
The written mandate, in French, must be signed before operations begin. The agent receives a dedicated VAT number, though a transitional tolerance allows operation without it until 31 December 2026. It files one electronic VAT return per period for all its principals, separate from its own return.
The agent is jointly and severally liable for VAT, interest and penalties if the conditions for exemption or suspension are not met. It must keep a transaction register for each principal until 31 December of the third year after the transaction year and provide it electronically within 20 days of a request.
This announcement was made on 14 October 2026.
