VAT Tax Representative

Tax Representative and Customs Obligations in France

Imports, customs duties, excise taxes, import VAT: understand how customs and tax obligations interact for non-residents bringing goods into France.

Customs and VAT: two authorities, two distinct obligations

In France, tax obligations related to imports involve two different authorities, which must not be confused:

  • The DGDDI (French Customs and Indirect Taxes Directorate): responsible for customs duties, excise duties (alcohol, tobacco, hydrocarbons) and customs clearance of goods entering the territory.
  • The DGFiP (French Public Finance Directorate): responsible for VAT, including import VAT following the 2022 reform that transferred collection of this tax to the DGFiP.

The accredited tax representative under Article 289 A of the CGI acts as a representative before the DGFiP for VAT obligations. It is distinct from the approved customs agent (customs representative) who acts before the DGDDI. A foreign company that regularly imports into France may need both professionals.

Import VAT reform Since 1 January 2022, import VAT is self-assessed directly on the VAT return of registered operators, and is no longer collected by customs. This reform reinforces the importance of French VAT registration and, for non-EU entities, the need for a tax representative.

Import VAT for non-residents

When a foreign company introduces goods from a third country onto French territory, it carries out an importation subject to VAT. The applicable rate is the standard rate of 20% (or the reduced rate for certain products such as foodstuffs or medicines).

Since the January 2022 reform, operators registered for VAT in France can self-assess this VAT directly on their CA3 return. In practice:

  • Import VAT is recorded as both output VAT (taxable transactions line) and input VAT (deductible VAT on non-capital goods line).
  • If the goods are intended for taxable transactions, the VAT neutralises itself and represents no cost to the company.
  • To benefit from this regime, the company must be registered for French VAT at the time of importation.
  • Non-EU companies that are not registered will have VAT demanded by customs at the time of clearance, with no possibility of recovery.
SituationImport VAT treatmentTax representative required
EU company registered in FranceSelf-assessed on CA3No
Non-EU company registered (with tax rep.)Self-assessed on CA3Yes (mandatory)
Non-EU company not registeredVAT demanded by customsNot applicable (non-compliant)

Excise duties: alcohol, tobacco, energy products

Excise duties are indirect taxes levied on the production, holding and movement of certain products: alcoholic beverages, manufactured tobacco products, energy products (fuels, gas) and electricity. They fall under the DGDDI and are governed by rules separate from VAT.

For a non-resident introducing these products into France, the main obligations are:

  • Alcohol and alcoholic beverages: mandatory appointment of an approved warehousekeeper or registered consignee with customs, who handles the formalities and payment of excise duties.
  • Tobacco products: strict monopoly regime, access limited to approved operators.
  • Hydrocarbons and energy: duty suspension warehouse regime managed by DGDDI-approved operators.
Practical example A US wine merchant wants to ship cases of wine directly to French private individuals. They must: 1) appoint an accredited tax representative for VAT (Article 289 A CGI); 2) ensure their shipments pass through an approved warehousekeeper for alcohol excise duties; 3) comply with customs filing obligations. These three obligations are independent of each other.

Practical steps for regularly importing into France

For a non-EU foreign company that regularly imports goods into France, the compliance process comprises several steps:

  • Step 1: Appoint a DGFiP-accredited tax representative for VAT obligations (Article 289 A CGI).
  • Step 2: The tax representative carries out VAT registration with the SIEE (Foreign Business Tax Office).
  • Step 3: Appoint an approved customs agent for customs formalities and management of customs duties.
  • Step 4: If products are subject to excise duties, appoint an approved warehousekeeper or registered consignee with the DGDDI.
  • Step 5: Set up monthly or quarterly VAT return flows with the tax representative.
Risk of goods seizure Goods imported by a non-EU company that is not registered for VAT and does not have a tax representative may be held by French customs, in addition to tax penalties. Prior compliance is essential for any regular importer.

Consult our list of DGFiP-accredited tax representatives to find a professional who will guide you through your import and VAT compliance procedures.

Frequently asked questions

No, these are two distinct regimes. The accredited tax representative (Article 289 A CGI) acts for VAT obligations with the DGFiP. Customs representation falls under a different regime (approved customs declarant or approved customs agent) overseen by the DGDDI. A company may need both professionals.
Import VAT is due when goods from third countries enter EU territory. It was historically collected by customs authorities. Following the reform, in France, registered taxable persons self-assess it directly on their VAT return (Article 1695 CGI), provided they are registered for French VAT — hence the role of the tax representative.
Alcoholic beverages are subject to excise duties in addition to VAT. A non-resident importing or dispatching alcohol into France must generally appoint a tax representative (approved warehousekeeper) with the customs authority (DGDDI), which is separate from the VAT tax representative. This obligation applies from the very first litre imported.
Yes, if it is registered for French VAT and the imported goods are used for taxable transactions. Import VAT that is self-assessed appears as both output VAT (taxable transactions line) and input VAT (deductible VAT on non-capital goods line) on the CA3 return. The tax representative manages this recovery within the scope of its mandate.
Goods may be held by customs. The company faces fines and surcharges for failing to have a VAT tax representative. Import VAT will be demanded but cannot be self-assessed without prior registration. Late payment penalties and a surcharge of 50% of the evaded duties may be applied.

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