If your business imports goods into France from outside the EU, a major VAT rule change is on the horizon. Starting 1 January 2026, France is introducing significant changes to the VAT treatment of non-EU businesses carrying out imports followed by intra-Community supplies. These changes, under Article 112 of the Finance Act No. 2023-1322, have important implications for compliance, cash flow and operational processes.
Abolition of the Occasional Tax Representation Regime
Until now, non-EU businesses could rely on the “occasional tax representation” (représentation fiscale ponctuelle) under Article 289 A (III) of the French General Tax Code (CGI). This one-off regime allowed import VAT to be declared by an appointed fiscal representative, without the need for the non-EU business to register for VAT in France.
With the new amendments, this regime will gradually be phased out, as France moves toward more consistent and transparent VAT reporting for imported goods.
Transition to the General VAT Regime
From January 2026 onwards, non-EU businesses importing goods for intra-Community supplies must comply with the General VAT Regime, which requires:
- Appointing a permanent fiscal representative in France
- Registering for VAT in France
This change aligns with the introduction of postponed accounting for import VAT, enabling businesses to declare VAT directly on their returns rather than paying upfront at the border. This is a welcome improvement for cash-flow management, especially for companies with significant import volumes.
Transitional period for smooth compliance
To ease the transition, the French tax authorities have issued BOI-RES-TVA-000207 (14 May 2025), granting a one-year extension for the occasional tax representation regime. During this period, until 31 December 2025, non-EU businesses can continue to:
- Use occasional fiscal representatives for imports
- Delay full VAT registration until the end of the transitional period
This window provides companies time to appoint a permanent fiscal representative and complete VAT registration formalities, ensuring a smooth transition to the new regime.
Impact for businesses
The changes will affect businesses in several key areas:
- Compliance obligations increase:
- Mandatory VAT registration: Non-EU businesses must register for VAT in France, even if they previously relied on occasional representation.
- Permanent fiscal representative: Appointing a permanent fiscal representative is now a legal requirement, increasing ongoing administrative responsibilities.
- Accurate reporting: Import VAT must be properly declared on VAT returns, rather than relying on ad-hoc arrangements.
- Cash flow management benefits:
- Postponed import VAT accounting: Businesses can declare import VAT directly on VAT returns instead of paying upfront at the border, reducing short-term cash outflows and improving working capital.
- Operational adjustments:
- System updates: Internal accounting and ERP systems may need adjustments to handle postponed accounting and integrate permanent fiscal representative details.
- Process changes: Businesses will need to implement new workflows for import declarations and intra-Community supply reporting under the general regime.
- Risk of non-compliance:
- Failing to register for VAT or appoint a permanent fiscal representative could result in penalties, delayed VAT recovery, or customs issues.
- Late adaptation may disrupt cash flow benefits from postponed accounting.
Key takeaways for businesses
Non-EU businesses importing goods into France should start preparing now to ensure full compliance by 1 January 2026.
Key steps include:
- Appoint a permanent fiscal representative to handle ongoing VAT obligations.
- Complete VAT registration to transition seamlessly from the occasional representation regime.
- Update internal processes to take advantage of postponed import VAT accounting.
By acting early, businesses can avoid last-minute compliance challenges and maintain smooth cash flow management under the new French VAT rules.
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At Fintua, we help businesses navigate regulatory changes with clarity and confidence. From VAT compliance to multi-jurisdictional tax processes, our experts and technology keep you ahead of change.
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Authors
Lisa Dowling
Specialising in International VAT Compliance solutions, Lisa brings a wealth of knowledge and insight in her dealings with a host of international clients ranging from start-ups through to multinationals. With 21 years VAT experience behind her, Lisa has managed VAT compliance issues and solutions globally for over 11 years. Fintua have 12,000 + corporate clients in over 109 countries and many of these are members of the Fortune 500.
