The principle of French VAT territoriality
French VAT applies to transactions where the place of taxation is located in France, under the rules set out in the French General Tax Code (CGI, Articles 256 to 259 D) and EU VAT Directive 2006/112/EC. It is therefore not the nationality or place of establishment of the seller that determines liability, but the nature and place of the transaction carried out.
For a foreign company, three main types of transaction can create a French VAT obligation: supplies of goods, intra-EU acquisitions and imports, and certain services. Understanding these rules is the first step before determining whether you need to register and, if so, appoint a tax representative.
Supplies of goods and storage in France
A supply of goods is taxable in France when the goods are on French territory at the time the sale is concluded and delivered. Several practical situations arise from this rule:
- Local sales from French stock: if you store products in a French warehouse — managed by yourself, a logistics provider or a marketplace such as Amazon FBA — sales from that stock are taxable in France.
- Intra-EU acquisitions: when a company in another EU member state transfers its own goods to France, it carries out an intra-EU acquisition taxable in France.
- Imports: the introduction of goods from third countries onto French territory is subject to import VAT, collected by customs or, since 2026, self-assessed via the VAT return (Article 1695 CGI regime).
- Intra-EU distance sales: sales of goods to French private individuals from another EU member state are subject to French VAT above the €10,000 annual threshold for intra-EU sales (OSS scheme).
| Transaction type | Place of taxation | Tax representative required (non-EU) |
|---|---|---|
| Stock in France sold locally | France | Yes |
| Import with VAT recovery | France | Yes |
| B2C distance sales (non-EU) | France | Yes |
| Intra-EU acquisition (EU company) | France | No (EU) |
Services: B2B and B2C rules
For services, the place of supply rules are more complex. The VAT Directive distinguishes two main regimes:
B2B services (between taxable persons): the general rule under Article 44 of the VAT Directive places the place of taxation where the customer is established. If your business customer is in France, it is the customer who is liable for VAT through the reverse charge mechanism. In this case, you are not required to register in France solely for these B2B services.
B2C services (to private individuals): the general rule places the place of taxation with the provider. However, many exceptions exist for electronic services, services relating to immovable property located in France, cultural or sporting events, etc. These B2C services deemed to be located in France create a VAT registration obligation.
When do these transactions trigger the tax representative obligation?
Article 289 A of the French General Tax Code (CGI) requires any company established outside the European Union that carries out taxable transactions in France to appoint an accredited tax representative, provided it is not covered by a mutual assistance agreement between its country and France.
In practice, the most common situations that trigger this obligation are:
- Sales of goods stored in France to French customers (individuals or businesses)
- Imports of goods with recovery of deductible VAT
- B2C services located in France (services relating to immovable property, electronic services above OSS thresholds, etc.)
- Any taxable transaction in France for which the reverse charge mechanism does not apply
To secure your situation, consult our list of DGFiP-accredited tax representatives who will guide you in identifying your obligations and achieving compliance.