Context: Chinese businesses in France
China is one of the world's leading suppliers of consumer goods, and Chinese businesses have a significant presence in the French market, whether through platforms such as Amazon, direct online stores (AliExpress, Shein, Temu…) or import-export operations. Since 2026, VAT rules have been substantially tightened: marketplaces are now jointly liable for collecting VAT, but this does not release sellers from their own obligations.
As China is not a member of the European Union, all Chinese entities with taxable transactions in France are subject to Article 289 A of the French General Tax Code, which requires the appointment of a fiscal representative accredited by the French Tax Authority (DGFiP).
VAT obligations for Chinese companies
A company established in China must appoint a fiscal representative in France in several situations:
- Storage of goods in France (own warehouse, 3PL logistics provider, Amazon fulfilment)
- Imports into France followed by local sales (obligation to pay import VAT then VAT on the sale)
- Direct sales to French consumers without a jointly liable intermediary
- Taxable services in France (e.g. B2C digital services above the OSS threshold)
The accredited fiscal representative handles registration with the SIEE (Service des Impôts des Entreprises Étrangères in Paris), obtains the VAT number, and then files CA3 returns on behalf of the Chinese company.
E-commerce and marketplaces: specific cases
The e-commerce VAT rules that came into force in July 2021 changed the allocation of responsibilities. For sales via Amazon, Cdiscount or Fnac, these platforms became jointly liable for collecting VAT on B2C sales under €150 from outside the EU. However:
- For direct sales (own shop, merchant website): a fiscal representative remains mandatory
- For storage in France (Amazon FBA with local warehouse): VAT on B2B sales and stock movements must still be declared through the fiscal representative
- For B2B services (software, subscriptions, SaaS sold to French businesses): reverse charge applies on the client's side, but registration may still be required
Chinese residents and real estate in France
A Chinese resident who owns property in France is subject to French taxation on rental income and on the capital gain on a disposal. The capital gains tax rate is 26.5% for non-EEA residents (19% income tax rate + 7.5% solidarity levy), to which additional social levies may be added depending on applicable treaties.
Appointing an accredited fiscal representative is mandatory when the capital gain exceeds €150,000. For sales below this threshold, the notary can withhold the tax directly. The Franco-Chinese tax treaty may reduce the overall tax burden, but does not remove the representation obligation.
To find a fiscal representative experienced in Franco-Chinese matters, consult the list of DGFiP-accredited fiscal representatives.
Appointing your tax representative: practical steps
The procedure follows the standard steps applicable to any non-EU entity:
- Select an accredited representative: verify their DGFiP approval and experience with Chinese entities (language skills, knowledge of Chinese legal structures)
- Assemble the file: articles of association translated into French, extract from the Chinese business register (营业执照), bank details, mandate letter
- Submit the registration application: to the SIEE, average processing time 4 to 8 weeks
- Obtain the VAT number: to be stated on all invoices and customs declarations for imports into France