Paris Administrative Court – ruling of 3rd June 2025, no. 2311477, SAS AetT France
In this case, following a tax audit, the French tax authorities questioned the VAT exemption on export sales made by a company during the audit period.
In practice, the Authorities subjected all of the company’s export transactions to VAT, on the grounds that they had not been given access to the company’s accounts or to supporting documentation.
The company appealed to the Paris Administrative Court.
The judges upheld the Tax Authorities’ position, ruling that “the mere production of export declarations not endorsed by Customs authorities, without any additional evidence, is insufficient to prove that the exports actually took place and that the goods left French territory.”
This ruling underlines the importance of holding supporting documents for VAT purposes, in order to justify the application of tax rules.
