VAT Tax Representative

Countries linked to France by a tax treaty: mandatory tax representative or not?

The obligation to appoint an accredited tax representative depends on the country of establishment. Some countries benefit from an exemption through mutual recovery assistance agreements. Find out where you stand.

The principle of treaty-based exemption

Article 289 A of the French General Tax Code (CGI) requires any company established outside the European Union that carries out VAT-taxable transactions in France to appoint an accredited tax representative. This representative is jointly and severally liable for the payment of VAT to the French tax administration.

However, the same article provides for an exemption for companies established in a country that has concluded with France an agreement on administrative and recovery assistance in tax matters. The logic is straightforward: if France can recover its tax claims directly in the debtor's country thanks to a mutual assistance mechanism, the guarantee provided by a local tax representative becomes less essential.

Two distinct types of agreement There are bilateral tax treaties to avoid double taxation (which are not sufficient on their own) and administrative assistance agreements including a recovery assistance clause (which can exempt from the VAT tax representative obligation). The existence of a double taxation treaty alone does not guarantee an exemption.

EU, EEA and non-EU countries: three different regimes

The VAT tax representative obligation under Article 289 A applies differently depending on where the foreign company is located:

  • European Union (27 member states): no VAT tax representative obligation. EU companies register directly with the SIEE. Filing obligations remain the same.
  • European Economic Area (Iceland, Liechtenstein, Norway): same regime as the EU, no mandatory tax representative.
  • Third countries with a recovery assistance agreement: possible exemption subject to conditions — the scope of the agreement must be verified.
  • Third countries without a sufficient agreement: accredited tax representative mandatory for any taxable transaction in France.

Non-EU countries with a relevant treaty

Some non-EU countries have concluded bilateral agreements with France that include sufficient recovery assistance mechanisms to be taken into account under Article 289 A of the CGI. Among the most common examples in practice:

  • United Kingdom (post-Brexit): the UK left the EU on 1 January 2021; since that date, UK companies are subject to the tax representative obligation, even though a double taxation treaty exists separately.
  • Switzerland: has an agreement with France. For VAT purposes, the exemption may apply in certain cases, but the situation must be analysed on a case-by-case basis.
  • Canada, Norway, Iceland, Liechtenstein: may benefit from specific provisions depending on the applicable texts.

The official list of covered countries and the exact conditions of application are set out in the Official Bulletin of Public Finance (BOFiP), notably in the documentation on VAT and obligations of non-established taxable persons.

Practical example A Norwegian company provides taxable services in France. Norway is part of the EEA. It can therefore register directly for French VAT without appointing a tax representative. However, if the same service is provided by a company based in Singapore — a country without a recovery assistance agreement with France — an accredited tax representative is mandatory.

Limits of the exemption: when a tax representative remains useful

Even when appointing a tax representative is not legally required, using an accredited professional is often still recommended. There are many practical reasons for this:

  • Managing VAT returns in French, in a filing system different from that of the home country
  • Recovering VAT credits, which requires exchanges with the French tax administration
  • Managing tax audits and requests for supporting documents
  • For real estate transactions, the accredited representative obligation persists for the capital gains withholding tax (Article 244 bis A CGI) above €150,000 of disposal proceeds, regardless of the VAT exemption
Do not confuse the regimes The VAT tax representative exemption (Article 289 A CGI) is distinct from the accredited representative obligation for real estate capital gains (Article 244 bis A CGI). A Swiss or Canadian national may be exempt for VAT purposes but still subject to the obligation for real estate capital gains.

If you are unsure about your situation, consult our list of DGFiP-accredited tax representatives for personalised advice from professionals specialising in international taxation.

Frequently asked questions

Not necessarily. France and Canada are linked by a bilateral tax treaty that includes administrative and recovery assistance clauses. A Canadian company carrying out taxable transactions in France can register directly for VAT, without a mandatory tax representative under Article 289 A of the French General Tax Code (CGI).
Switzerland is not in the European Union, but has a tax treaty with France that includes recovery assistance. This may exempt it from the VAT tax representative obligation. However, for the withholding tax on real estate capital gains (Article 244 bis A CGI), an accredited representative remains mandatory if the gain exceeds €150,000.
No. Despite the French-US tax treaty, the United States does not benefit from a full exemption from the VAT tax representative obligation. US companies carrying out taxable transactions in France remain required to appoint an accredited tax representative under Article 289 A of the CGI.
The French tax administration publishes the list of countries with which France has concluded mutual recovery assistance agreements. This list is found in the BOFiP (Official Bulletin of Public Finance). If in doubt, consulting a tax representative or international tax expert is recommended.
No. The exemption from the mandatory tax representative does not remove the VAT obligations themselves. The company still needs to register for French VAT and file returns with the SIEE. It can simply do so directly, without going through a legally required accredited representative.
Official sources: BOFiP — Art. 289 A CGI — impots.gouv.fr — Legifrance — CGI Art. 289 A

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