VAT fraud costs EU Member States billions every year. Electronic invoicing has emerged as one of the most effective weapons against it, making transactions visible to Tax Authorities in real time and significantly reducing the opportunities for fraud.
Against this backdrop, Member States have each been developing their own frameworks, with varying approaches and timelines. The ViDA initiative (VAT in the Digital Age), led by the European Commission, aims to harmonise these obligations across the EU for cross-border transactions, while domestic transactions remain the responsibility of each Member State.
The French reform has generated plenty of discussion for businesses established in France, but it’s been far less covered when it comes to foreign companies that simply hold a French VAT number. Yet they’re not off the hook. So, what does this reform actually mean for them?
E-invoicing and e-reporting: understanding the two pillars of the French reform
The French reform revolves around two separate obligations that are regularly mixed up, and it’s worth being clear on both.
- E-invoicing refers to the requirement to issue and receive electronic invoices through approved third-party platforms known as “Plateformes Agréées” (PA) in French. This applies to B2B transactions carried out between businesses established in France.
- E-reporting is a different beast altogether. It’s about periodically sending transaction data to the French Tax Authorities, and it picks up where e-invoicing leaves off, covering operations that fall outside that framework.
For businesses not established in France, knowing which obligation applies to them, and when, is exactly what this reform is about. And despite their different scopes, both run through the same technical infrastructure: the “Plateformes Agréées”.
What the reform actually means for non-established businesses.
Before diving in, it’s worth being clear about who we’re talking about. A foreign company with no permanent establishment in France can still be VAT-registered there if it carries out certain operations on French territory, whether that’s storing goods, trading, or selling online. These businesses hold a French VAT number without being fiscally established in the country. That’s exactly the profile this article is aimed at.
Here’s the good news: these companies are completely off the hook when it comes to e-invoicing, on both the issuing and receiving side. If your business is based abroad and simply holds a French VAT number, you have no obligation to issue invoices through a PA or plug into a platform to receive them. French partners or clients might push back on this, but their obligations are theirs to deal with, not yours.
E-reporting is a different story. This is where foreign VAT-registered companies may well have real obligations, and it’s the part most businesses get wrong or overlook entirely. Not every transaction is in scope, though, and the real work is in pinning down which operations are caught and when you need to be compliant.
To cut through the complexity, here is a breakdown of the transactions subject to e-reporting for foreign companies with a VAT registration in France. Worth noting: the scope is narrower than it is for established businesses.
Transation type | E-reporting | Entry into force |
Sales with collected VAT (ie : B2C sales not reported through OSS, B2B sales to non-VAT registered entities) | Yes | September 2026 / Setpember 2027 Depending on the company size |
Transactions with reverse charge VAT (ie : Intra-Community acquisition of goods) | Yes | September 2027 |
Imports, domestic purchases, Intra-Community supply of goods, export | Out of scope | |
E-reporting in France : does it apply to me ? Three real-life scenarios
Scenario 1 — B2C e-commerce sales shipped from a French warehouse
A foreign company is VAT-registered in France and holds stock on French territory, from which it fulfils orders for French consumers through its e-commerce website.
These B2C sales are squarely within the scope of e-reporting. The company will need to report the relevant transaction data to the French Tax Authorities.
Scenario 2 — B2B sales with reverse charge VAT
A foreign company is VAT-registered in France. It imports goods from a Third country under DDP incoterms and delivers them directly to French VAT-registered customers. The invoices are issued net of VAT in line with French rules, and it’s the French customer who accounts for the VAT under the reverse charge mechanism.
In this case, the e-reporting obligation sits with the French customer. The foreign company has nothing to report on these transactions.
In practice, not charging VAT on a transaction doesn’t always mean there’s nothing to declare. On this specific point however, non-established businesses are genuinely in the clear.
Scenario 3 — a business with multiple transactions
Let’s look at a more complex example, one that reflects what we see regularly in practice.
A UK company is VAT-registered in France because it holds stock there. That stock is replenished from the UK, but also from European and French suppliers. The company sells to business customers in France and across the EU, and to French consumers through its own e-commerce website.
This company needs to work out which transactions fall under e-reporting and from what date it needs to be filing. The answer depends on the size and consolidated financial data of the entity at global level, not just the volume of operations carried out on French territory. That’s a detail that catches a lot of businesses off guard.
Here’s how the obligations break down, transaction by transaction:
| Transaction type | E-reporting ? | From when ? |
| Imports from the UK | No | — |
| Intra-Community acquisition of goods (from EU suppliers) | Yes | 2027 |
| Local purchases from French suppliers | No | — |
| B2B sales to French VAT registered entities | No | — |
| Intra-Community supplies of goods | No | — |
| B2C sales to French consumers | Yes | 2026 or 2027* |
*Depending on the size and consolidated financial data of the entity at global level.
This table illustrates a key point: having multiple transactions does not mean being subject to e-reporting across the board. The analysis has to be done transaction per transaction.
In practice, for this UK company:
- If it qualifies as a large enterprise at global level, e-reporting on its B2C sales kicks in from 2026.
- If it falls into another category, that obligation only applies from 2027, at which point Intra-Community acquisitions of goods from its European suppliers come into scope as well.
All other transactions, including French purchases, B2B sales with reverse charge and Intra-Community supplies, remain out of scope regardless of company size.
Before the deadlines land, here’s where to focus
For non-established businesses with a French VAT number, preparation comes down to a few key steps :
- The first is mapping your transactions. Before anything else, you need a clear picture of which operations fall under e-reporting and which don’t. This is where most mistakes happen.
- The second is nailing down your timeline. When your obligations kick in depends on criteria assessed at global company level, not just your French operations. It’s not something to gloss over.
- The third is getting the right transmission solution in place. E-reporting has to go through an accredited PA, so your invoicing tools need to be able to produce the right data in the right format.
From VAT management to e-reporting: one point of contact
For non-established businesses with a French VAT number, this reform is about more than just electronic invoicing. The real question is whether certain transactions trigger e-reporting obligations, and if so, when and how to deal with them in practice.
At Easytax, we already support a large number of foreign companies with their French VAT registration and compliance obligations. That day-to-day knowledge of your operations means we can approach the reform practically, without overcomplicating things.
We can help you map your transactions, identify which flows are in scope, confirm the timeline that applies to your business and put the right solution in place for transmitting the required data.
Not sure whether any of this applies to you? Get in touch and we’ll help you work it out, so you can get ahead of your French obligations with confidence.
