Brexit & French VAT

Brexit and VAT in France: do British companies need a tax representative?

Since 1 January 2021, the United Kingdom is a third country. British companies carrying out taxable transactions in France are required to appoint a VAT tax representative accredited by the DGFiP.

The impact of Brexit on VAT obligations in France

Before 31 December 2020, British companies benefited from the EU regime: they could register directly for French VAT without a mandatory intermediary. Since 1 January 2021, the date of the United Kingdom's effective departure from the European single market, this facility no longer exists.

British companies are now treated like any company established outside the European Union. Article 289 A of the French General Tax Code applies in full: any taxable transaction in France carried out by a British entity requires the appointment of a tax representative accredited by the French Tax Authority (DGFiP).

This change affects UK Ltd companies, LLPs, and PLCs, as well as British self-employed individuals carrying out taxable services in France, provided they do not have a permanent establishment on French territory.

Key date Brexit for VAT purposes took effect on 1 January 2021. British companies that had a direct VAT registration were required to appoint an accredited tax representative. Those who delayed are potentially exposed to retroactive penalties.

Which British companies are affected?

The tax representative obligation applies to any British company without a permanent establishment in France that carries out at least one of the following transactions:

  • Sale of goods located in France: stock in a French warehouse (including Amazon FBA UK using FR warehouses), sales from a trade fair or exhibition in France.
  • Import of goods from the United Kingdom or a third country to France, followed by local resale.
  • Taxable services in France: building works, certain cultural and event services.
  • Distance sales of new goods to French consumers (above the OSS threshold, which is not accessible to non-EU companies).
  • Intra-community acquisitions: a British company that buys goods in an EU country and ships them to France is affected.
Notable exception B2B services subject to the reverse charge mechanism in France do not necessarily require a French VAT registration for the British company. It is the French taxable customer who collects and remits the VAT. Check your situation on a case-by-case basis.

Steps to achieve post-Brexit compliance

If your British company carries out taxable transactions in France and does not yet have an accredited tax representative, here is the procedure to follow:

  • Identify taxable transactions: take stock of the flows of goods and services carried out in France since 1 January 2021.
  • Appoint a DGFiP-accredited tax representative: sign a representation mandate with an approved professional. Our list of accredited representatives includes firms specialising in Anglo-Saxon companies.
  • Regularise outstanding returns: if taxable transactions took place without a return being filed since January 2021, a voluntary regularisation reduces the applicable penalties.
  • Obtain or update the FR VAT number: the tax representative submits or updates the file with the SIEE (Foreign Companies Tax Office) in Noisy-le-Grand.

Special cases and atypical situations

Several situations deserve particular attention for companies and individuals with ties to the United Kingdom.

  • French expatriates in the UK who own property in France: they are not subject to the VAT tax representative obligation, but may be subject to the accredited tax representative for capital gains if the sale price exceeds €150,000.
  • Amazon FBA from the United Kingdom: a seller using Amazon warehouses in France from the UK has a VAT tax representative obligation. Confusion with the OSS (One-Stop Shop) scheme is common — OSS is not accessible to non-EU companies without an EU establishment.
  • Groups with a French subsidiary: if the French subsidiary is a separate entity registered in France, it manages its own VAT. But intra-group flows between the British parent company and the French subsidiary may create additional obligations.
Urgent regularisation British companies that have not appointed a tax representative since January 2021 are potentially liable to a VAT reassessment covering several years, with surcharges and late interest. A voluntary regularisation process is strongly recommended before any tax audit.

To find an accredited tax representative with experience in British companies, consult our list of DGFiP-accredited tax representatives. Several firms there specialise in Anglo-Saxon and English-speaking clients.

Frequently asked questions

The obligation has applied since 1 January 2021, the date on which the United Kingdom officially left the European single market. Since that date, British companies are treated like any non-EU company and must appoint a DGFiP-accredited tax representative for their taxable transactions in France.
Ireland remained in the EU and is therefore not affected by Brexit. The Isle of Man, a British Crown dependency, has a special situation: it is part of the EU customs territory for VAT on goods but not for services. Its situation must be examined on a case-by-case basis with a professional.
If the French subsidiary is a separate legal entity (SAS, SARL, etc.) established in France, it can manage its own French VAT obligations without a tax representative. However, if the UK Ltd itself carries out taxable transactions in France (not through the subsidiary), the accredited tax representative remains mandatory for those direct transactions.
Not necessarily. The accredited VAT tax representative for commercial transactions may be different from the representative accredited for capital gains withholding on real estate. These two accreditations are granted by different DGFiP departments. Check that your representative holds the accreditation appropriate to your situation.
Yes, France and the United Kingdom are bound by a bilateral tax treaty covering income tax and corporation tax. However, this treaty does not exempt British companies from the VAT tax representative obligation. VAT and double taxation conventions are two entirely separate regimes.
Official sources — impots.gouv.fr — BOFiP — legifrance.gouv.fr

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