Stock in France = automatic VAT obligation
This is one of the least-known triggers of French VAT obligations for foreign businesses: the mere fact of holding a stock of goods on French territory is sufficient to create a VAT obligation, regardless of whether you have an office, employees or a permanent establishment there.
Under French tax law, the storage of goods in France constitutes a "taxable operation" within the meaning of Article 256 of the French General Tax Code (CGI). For businesses established outside the European Union, this also triggers the obligation to designate a tax representative accredited by the French Tax Authority (DGFiP), in accordance with Article 289 A of the CGI. There is no grace period or minimum threshold.
Common storage scenarios in France
Storage in France takes many forms. Here are the most frequent situations encountered by foreign e-commerce merchants and importers:
- Amazon FBA France — Amazon automatically distributes your stock across its European warehouses, including in France. You do not always choose the storage country, but the VAT obligation applies as soon as stock is in France.
- 3PL logistics provider — You use a French logistics operator (Geodis, DHL Supply Chain, ID Logistics…) to store your goods and ship them to customers. This model creates an identical VAT obligation.
- Own warehouse — You rent or own a warehouse in France. In addition to VAT obligations, this may also create a permanent establishment for corporate tax purposes.
- Consignment stock — Your goods are stored with a French distributor or reseller pending sale. This consignment regime has been subject to specific VAT rules since 2020 (Article 17a of the VAT Directive).
- Marketplace fulfilment centre — Cdiscount, Zalando, Leroy Merlin Marketplace… many platforms offer fulfilment services with storage in France.
Compliance steps
VAT compliance should ideally be obtained before the first stock movement in France. Here is the standard procedure for a non-EU business:
Before sending stock to France: designate an accredited tax representative and initiate the VAT registration application. The VAT number processing time is 4 to 8 weeks. Planning ahead is essential to avoid a period of non-compliance.
At registration: provide your tax representative with all required documents (company registry extract, articles of association, mandate agreement). Once the VAT number is obtained, it is communicated to your logistics providers and platforms.
On an ongoing basis: your tax representative files CA3 returns and manages VAT flows on purchases, sales and intra-community stock movements.
Specific points of attention
Storage in France raises several tax questions beyond simple VAT:
- Intra-community acquisitions — If your goods arrive from another EU country, they are subject to French VAT through the intra-community acquisition mechanism, to be declared on the CA3 return.
- Stock transfers between member states — Sending goods from your French warehouse to another EU country constitutes an intra-community supply to be declared.
- Corporate tax permanent establishment risk — Significant stock managed by personnel or through an extensive logistics contract may, in some cases, be classified as a permanent establishment for corporate income tax purposes. This point is distinct from VAT and warrants specific analysis.
To anticipate these obligations before your first stock shipment to France, consult our list of accredited tax representatives specialising in e-commerce and logistics.