VAT Tax Representative

Invoicing and Mandatory Mentions with a VAT Tax Representative

VAT number, tax representative details, reverse charge notice: master the invoicing rules that apply when operating in France through an accredited tax representative.

The invoicing obligation in France

In France, any VAT-registered company that supplies goods or services for consideration is required to issue an invoice to its business customers (B2B). This obligation is set out in Article 289 of the French General Tax Code (CGI). For B2C sales, an invoice is mandatory on request from the customer, but spontaneous issuance is required for significant amounts.

For a foreign company represented in France by an accredited tax representative, French invoicing rules apply in full as soon as the transactions are located in France. No preferential regime or exemption exists for non-residents in terms of invoicing.

Golden rule An incomplete or incorrect invoice can lead to the rejection of the customer's VAT deduction and exposes the issuer to penalties. The tax representative checks that your invoice templates are compliant before you begin trading in France.

Mandatory mentions on French VAT invoices

Article 289 of the CGI lists the mandatory mentions that every invoice subject to French rules must include:

  • Issue date of the invoice
  • Invoice number — unique and sequential (no gaps or duplicates)
  • Seller/provider identity: name or company name, full address, French intra-EU VAT number
  • Customer identity: name or company name, address, intra-EU VAT number (for EU business customers)
  • Description of goods or services: precise designation, quantity, nature
  • Delivery or performance date (if different from the invoice date)
  • Unit price before tax and, where applicable, discounts, rebates
  • Applicable VAT rate (20%, 10%, 5.5%, 2.1%)
  • VAT amount corresponding to each rate
  • Total amount including all taxes (TTC)

For a non-resident company represented by a tax representative, invoices must additionally show the tax representative's details (name, address) as the regulatory point of contact in France. Certain French tax authority departments may require this information during audits.

MentionMandatory B2BMandatory B2C
Sequential invoice numberYesYes
Seller's VAT numberYesYes
Customer's VAT numberYes (if EU)No
VAT rate and amountYesYes
Tax representative's detailsRecommendedRecommended

The tax representative's role in invoicing

The accredited tax representative does not issue invoices on behalf of the foreign company. Its role in invoicing is primarily advisory and supervisory:

  • It checks the compliance of invoice templates before use
  • It ensures the French VAT number is correctly stated
  • It collects invoicing data to prepare periodic VAT returns
  • It manages disputes and regularisation requests with the administration
  • In the event of a tax audit, it provides invoices and supporting documents to inspectors

The tax representative holds a legal mandate to represent the foreign company before the French tax administration. It is jointly and severally liable for the payment of VAT, which provides a strong incentive to ensure correct invoicing and declaration of all taxable transactions.

Special cases: reverse charge, exemption, margin scheme

Certain transactions require specific mentions on invoices, in addition to the standard mandatory mentions:

  • Reverse charge: for B2B services supplied by a foreign provider to a French taxable customer, the invoice must state "Reverse charge — VAT to be accounted for by the recipient — Article 196 of Directive 2006/112/EC" and must not show any VAT amount.
  • VAT exemptions: the legal basis for the exemption must be stated (e.g. "Exemption Article 262 ter I CGI" for intra-EU supplies).
  • Margin scheme: for dealers in second-hand goods, the mention "Special scheme — Second-hand goods — Article 297 A CGI" is required.
  • Invoices in foreign currency: the VAT amount must be converted into euros at the exchange rate on the date VAT becomes chargeable.
Practical example A US company sells industrial equipment to a French company. It is registered for VAT in France through its tax representative. Its invoice must include its French VAT number (FR XX XXXXXXXXX), the applicable VAT rate (20%), the net amount, the VAT amount and the gross total. It must also show the details of its accredited tax representative.
Penalties for incorrect invoicing A fine of €15 per missing or incorrect mention applies, with a minimum of €60 and a maximum of 25% of the transaction amount. In cases of proven fraud, criminal penalties may also apply. The tax representative shares joint and several liability for the VAT relating to the transaction.

To ensure your invoices are compliant, consult an accredited DGFiP tax representative who will review your invoice templates and advise you on the mentions appropriate to your situation.

Frequently asked questions

Yes, when a non-resident company carries out taxable transactions in France through its tax representative, invoices must include the tax representative's details, notably its name or company name and address, in addition to the standard mentions relating to the foreign taxable person.
The French intra-EU VAT number obtained at the time of SIEE registration must appear on the invoices. This number is assigned to the foreign company itself, not to the tax representative. The tax representative has its own VAT number, which it uses for returns.
Mandatory mentions (Article 289 CGI) include: sequential invoice number, date, seller identity (name, address, French VAT number), customer identity, description of goods or services, quantity, unit price before tax, applicable VAT rate, VAT amount, total including tax. For special regimes (reverse charge, exemption), the corresponding legal notice must be added.
"Reverse charge" (or "VAT to be accounted for by the recipient — Article 196 of Directive 2006/112/EC") must appear on B2B service invoices where the French-established customer is liable for the VAT. In this case, the invoice is issued net of tax by the foreign provider, with no VAT charged.
A corrective invoice (or credit note) must be issued that cancels and replaces the erroneous invoice. The corrective invoice must reference the original invoice. The tax representative must be informed of any correction as it may affect returns already filed and require amended returns.

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