France – VAT refund claims: proof of authority required to act on behalf of foreign companies

Judgement of the Paris Administrative Court of Appeal of the 13th June 2025, No. 24PA01668 – Meda AB

In this judgment, the Paris Administrative Court of Appeal confirmed that anyone acting on behalf of a foreign company in dealings with the French Tax Authorities must show proper authority to represent that company, for example, when submitting a VAT refund claim.

Under Articles R.431-6 of the Code of Administrative Justice and R.197-4 of the Tax Procedures Code, “any person acting for a company must produce a valid power of attorney.”

In this case, the refund application had been signed by the company’s Chief Financial Officer, but no power of attorney had been provided and the request from the Authorities to rectify the omission went unanswered.

The Court held that being a CFO was not enough to establish the capacity to represent the company. It also dismissed the possibility that the individual could act as a board member, as this capacity had neither been mentioned nor relied upon.

This decision underlines the importance of strict formalities in dealings with the French tax administration. Sometimes, turning to a specialists is essential !

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