VAT & fiscal representation

Non-EU company: your VAT tax representative in France

Any company established outside the EU that carries out taxable transactions in France is required to appoint an accredited VAT tax representative. Here is what this means in practice.

Why non-EU companies are specifically affected

French tax law imposes a clear rule: any company that is not established in the European Union and that carries out VAT-taxable transactions in France must appoint an accredited tax representative. This obligation is set out in Article 289 A of the French General Tax Code (CGI) and allows for very few exceptions.

Unlike EU-established companies, which can register directly for French VAT or use the OSS One-Stop Shop, non-EU companies cannot represent their own French tax interests. The tax representative is therefore their legal agent before the DGFiP: they sign returns on the company's behalf, respond to the administration's requests, and assume joint and several liability.

Basic rule US, Australian, Canadian, Chinese or any other non-EU company selling in France? The obligation to appoint an accredited tax representative applies from the very first taxable transaction on French territory.

Which transactions trigger the obligation?

The obligation arises as soon as the foreign company carries out a VAT-liable transaction in France. The most common cases are:

  • Sale of goods located in France: goods stored in a French warehouse (including via Amazon FBA or any 3PL), new real estate, auction sales.
  • Import followed by resale: goods imported from outside the EU and sold to French customers generate French VAT that must be collected and remitted.
  • Services located in France: building works, cultural or sporting events, certain specific B2C services.
  • Intra-community acquisitions: purchase of goods from another EU member state destined for France.
  • Transactions as a taxable recipient: under the reverse charge mechanism, certain B2B transactions nevertheless require French registration.
Special case — OSS The OSS (One Stop Shop) allows intra-EU distance sellers to declare their VAT in a single member state. But this mechanism is not accessible to non-EU companies without an EU establishment for goods sales. These companies must go through an accredited tax representative.

Appointment and registration: the concrete steps

The procedure for appointing a tax representative in France follows a clearly defined process. Here are the key steps:

  • Step 1 — Choose a DGFiP-accredited representative: the representative must be approved by the French Tax Authority (DGFiP). Without accreditation, the mandate has no legal value.
  • Step 2 — Sign the representation mandate: a contract specifies the scope of the engagement, the mutual obligations, and the terms of any bank guarantee.
  • Step 3 — Submit the VAT registration file: the representative submits the application to the Foreign Companies Tax Office (SIEE) in Noisy-le-Grand, which is competent for all foreign companies with no establishment in France.
  • Step 4 — Obtain the FR VAT number: the administration assigns an intra-community VAT number beginning with FR, enabling the company to invoice with French VAT.
Concrete example A Canadian company sells SaaS software to French businesses. Although subject to reverse charge VAT by the buyer (B2B), certain transactions require a French VAT registration. Its accredited tax representative handles the SIEE file and manages the quarterly CA3 returns on its behalf.

Ongoing obligations managed by the tax representative

Once appointed, the tax representative continuously handles several reporting and compliance tasks:

  • Filing VAT returns (monthly or quarterly CA3 depending on the regime)
  • Preparing intra-EU goods movement declarations (DEB) or service declarations (DES) where applicable
  • Managing VAT credit refunds from the French tax authorities
  • Responding to information requests and audit notices from the DGFiP
  • Maintaining the register of taxable transactions and retaining supporting documents
  • Notifying any changes affecting the situation of the principal company
Joint and several liability The tax representative assumes joint and several liability for the payment of VAT. They may therefore sometimes require a bank guarantee or advance payments from the principal company. This requirement is legitimate and legal: review these conditions carefully before signing the mandate.

To identify an accredited tax representative with experience in your sector, consult our list of DGFiP-accredited tax representatives, with a comparison by speciality and type of clientele.

Frequently asked questions

Yes, as soon as it carries out transactions subject to French VAT (sales of goods located in France, taxable services in France), the obligation applies regardless of volume. There is no minimum threshold for non-EU companies, unlike intra-EU distance sellers who benefit from the €10,000 OSS threshold.
VAT registration in France assigns the foreign company a number starting with FR followed by 11 digits. This number is used for CA3 returns, intra-EU exchanges (DEB/DES), and invoicing. It is obtained through the accredited tax representative at the Foreign Companies Tax Office (SIEE) in Noisy-le-Grand.
The absence of an accredited tax representative exposes the company to fines of up to €750 per infringement, rejection of its returns, and a tax reassessment covering the last 3 years with late payment penalties (10% to 40%). Customs may also block goods at import in the absence of a representative.
Yes. An accredited tax representative can simultaneously represent several foreign companies before the DGFiP. Each mandate is distinct and subject to a separate accreditation. This is precisely why specialised firms can offer competitive rates thanks to economies of scale.
No. The mandate can be terminated at any time, subject to complying with the contractual terms and informing the tax authorities. It is essential to appoint a new representative simultaneously to avoid being in an irregular situation.
Official sources — impots.gouv.fr — BOFiP — Official French Tax Bulletin — legifrance.gouv.fr (Art. 289 A CGI)

Do you need an accredited tax representative ?

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