Tax Representation Services

What our tax representative in France service delivers

Our scope as tax representative in France is built around six work blocks, each partner-supervised and integrated with the wider tax and bookkeeping functions in the same Paris office.

• VAT registration and tax ID. We file the demande d’immatriculation with the Service des Impôts des Entreprises Étrangères (SIEE), obtain the French VAT number, and register the taxpayer for intra-EU operations. For sole traders and non-resident individual operators, the tax ID is the numéro SIRET, obtained through the same channel.
• Periodic returns and filings. We prepare the monthly or quarterly CA3 return, the annual CA12 where applicable, the Déclaration d’échanges de biens (DEB) and the Déclaration européenne de services (DES), monitoring the filing calendar to avoid late submissions and reverse-charge errors.
• Refunds and credit recovery. We file recovery applications under the 8th Directive (EU groups), the 13th Directive (non-EU groups), and the special procedure for non-established taxable persons, tracking each reimbursement and replying to information requests.
• DGFiP correspondence and inquiries. We hold the pouvoir (power of attorney) needed to act on behalf of the taxpayer and to receive every notice, formal letter, and inspection notification at our Paris address. We handle phone, email, and documentary correspondence with the DGFiP, the SIEE, and French Customs.
• Inspection assistance. Where the DGFiP opens an inspection, our partners attend in person, prepare the dossier, and represent the taxpayer through the vérification de comptabilité procedure. We coordinate with the foreign attorney or in-house counsel where the matter moves into appeals or formal dispute.
• E-reporting and continuity. Under the 2026–2027 French e-invoicing reform, every taxable person carrying out B2B operations in France must connect to a plateforme de dématérialisation partenaire (PDP) and continue e-reporting on cross-border flows. We connect the billing system to a PDP and ensure the feed remains current.

When a tax representative in France is mandatory and when it is optional

Pursuant to Article 289 A of the Code général des impôts, the engagement of a représentant fiscal is mandatory when three conditions are met together:

1. The taxpayer is established outside the European Union, and
2. The country of establishment has no mutual-aid arrangement with France on VAT recovery, and
3. The taxpayer carries out taxable operations in France — supplies of goods, supplies of work with French place of supply, intra-EU operations transiting through France, or B2C distance sales above the OSS threshold.

For EU-established groups, no mandatory representative is required. An EU operator that is VAT-registered in France files directly or through a mandataire fiscal — a delegate without joint liability. The remit of the mandataire fiscal is operationally similar but legally lighter: the EU operator retains primary responsibility, and the agent acts as a procedural delegate.

Several non-EU jurisdictions benefit from mutual-assistance agreements that exempt them from the mandatory engagement requirement. The United Kingdom, Norway, Iceland, the Faroe Islands, and a few others are in that category. A UK company is, since Brexit, free to register for French VAT directly with the DGFiP or to appoint a mandataire fiscal on a voluntary basis. In practice, many UK and Swiss firms choose a French fiscal agent for operational reasons (language, deadlines, audit interface) even where the engagement is not legally required.

The choice matrix for choosing between mandatory engagement, voluntary fiscal agency, and direct registration is shaped by the volume of French operations, the type of customers (B2B or B2C), the presence of imported goods, and the planning horizon for a potential French entity. The practical call is rarely about the form alone; it is about how the foreign taxpayer wants to manage its French VAT footprint over time.

In France vs. internationally

French fiscal representation rules are stricter than the equivalent regimes in several other countries. A few comparative points worth noting for any tax director or attorney shaping a cross-border VAT strategy:

• France vs. Germany. Germany requires no general fiscal agent for non-EU firms; registration is direct with the Finanzamt. France imposes joint liability through the représentant fiscal, which is a heavier status than the German model.
• France vs. Italy. Italy applies a similar rappresentante fiscale regime to non-EU firms without mutual-aid arrangement, but the Italian regime allows direct identification through the identificazione diretta route, which France does not.
• France vs. the United Kingdom. Post-Brexit, the UK applies its own VAT framework outside the EU VAT system. UK firms selling into France need to manage French VAT under the EU framework while their UK VAT obligations sit under HMRC and the UK government’s online portal. The two systems do not connect automatically.
• France vs. the United States. The US has no federal VAT; cross-border services are governed by sales-and-use tax rules that vary by state. A US firm operating in France must file French VAT returns through a représentant fiscal or mandataire fiscal, while its US federal tax filings sit with the IRS. The French and US authorities exchange information under the FATCA agreement and the OECD CRS, but the VAT and the federal income-tax filings remain separate. A US taxpayer with a French branch will typically also pay personal-income tax in France on the French-source revenue earned through that branch; the French and US filings need to be aligned to avoid double taxation under the 1994 France-US treaty.

A non-EU group operating across the EU often needs a coherent VAT strategy that pairs French representation with German direct registration, an Italian rappresentante fiscale, and an OSS or IOSS scheme for B2C distance sales. We coordinate the French side and work with trusted partner firms on the other jurisdictions where needed.

The French regulatory landscape

Fiscal representation in France is anchored in a layered framework of French legislation, EU directives, and administrative doctrine. The named entities and texts to know:

• DGFiP — Direction Générale des Finances Publiques. The French national tax administration. The DGFiP issues the VAT identification number, processes returns, and runs the audit and refund procedures.
• OEC — Ordre des Experts-Comptables. The professional body governing chartered accountants in France. Interexco is a member firm; our part as a fiscal representative is performed under OEC supervision and the indemnity protection of regulated practice.
• CNCC — Compagnie Nationale des Commissaires aux Comptes. The body governing statutory auditors. Where the foreign group operates through a French entity that crosses the audit thresholds (bilan ≥ 5 M€, CA HT ≥ 10 M€, ≥ 50 employees on two consecutive fiscal years — Décret n° 2024-152 du 28 février 2024, transposing EU Directive 2023/2775), a commissaire aux comptes is appointed.
• Code général des impôts (CGI). Article 289 A on mandatory engagement; Article 286 ter and following on registration, returns, and refunds; Article 278 on the 20% standard rate.
• Bulletin Officiel des Finances Publiques (BOFiP). The DGFiP’s administrative doctrine and regulations on VAT registration, fiscal representation, refund mechanisms, and the e-invoicing reform. The BOFiP is updated regularly; we monitor the December and June update cycles to keep the foreign group current.
• EU Directive 2006/112/EC (VAT Directive) and Council Implementing Regulation (EU) No 282/2011 (place-of-supply rules). The common EU framework.
• EU Directive 2008/9/EC and 13th Directive (86/560/EEC). VAT refund procedures for EU and non-EU groups.
• Loi de finances 2024. The e-invoicing rollout: large enterprises from September 2026; SMEs by September 2027.
• Loi Informatique et Libertés and CNIL guidance. Private data handling, including the identification information of the foreign group’s officers and customers. We share no information with parties outside the engagement without written authorization.

The French représentant fiscal is jointly liable for the foreign taxpayer’s French VAT and is subject to ethical standards under the OEC framework. Our part as a fiscal representative includes ongoing compliance assessment, identification of risks, and direct interaction with the DGFiP — not a documentary delegation. Our partners hold the expert-comptable qualification; for items that move into formal litigation we work alongside the foreign group’s attorney of choice.

Industries served

Our fiscal representation engagements typically cover:

• US, UK, and other non-EU companies with French sales or operations triggering French VAT registration. We sit alongside the foreign group’s domestic CPA or attorney as the central point of contact for the DGFiP.
• Manufacturing and distribution groups with goods transiting through France for EU distribution. The reverse-charge mechanism, the autoliquidation of import VAT, and the DEB filing are routine here.
• Online sellers and marketplace operators exceeding the EU distance-selling threshold. The OSS and IOSS schemes interact with the French VAT ID, and the e-reporting reform changes how each transaction must be recorded.
• Real property investors and family offices holding French immovable assets where rental revenue, sale proceeds, or inheritance distributions generate French VAT and private-client obligations.

How to choose a tax representative in France

Qualified firms handling this role in France fall into three categories: OEC-regulated chartered accountancy firms, law firms with a tax department, and unregulated administrative agencies. Only the first two carry the indemnity protection and ethical standards that French law associates with regulated practice.

The key criteria a tax director should check:

• Regulated status and joint liability capacity. Verify OEC membership or law-firm registration as the first check. The représentant fiscal is jointly liable for the foreign taxpayer’s French VAT — the firm’s balance sheet and indemnity coverage must make that liability credible. A small unregulated provider with no capital backing is a structural exposure.
• Languages and DGFiP relationships. The DGFiP corresponds in French; the foreign finance team may work in English, German, or another language. Check the firm’s working languages and its track record with the Service des Impôts des Entreprises Étrangères, French Customs, and local DGFiP offices. We work in English, French, Italian, Spanish, and Russian.
• Integrated scope and partner continuity. Combining representation with bookkeeping inside the same regulated firm avoids duplication and version-control errors. At Interexco, the same partner handles the engagement from registration through routine returns to inspection defence — continuity reduces the risk of losing a key DGFiP relationship mid-procedure.
• Cost transparency. Each engagement letter sets out the price schedule, response times, scope of inquiries covered, and items falling outside the standard scope. We provide a tailored quote at the start of the engagement.

The decision process should include reading the engagement document line by line, verifying the firm’s regulated standing with the OEC, and asking for two or three reference engagements in the same industry.

Common issues and dealing with the French tax authorities

The frequent issues we are asked to resolve include:

• Reassessment from the DGFiP. A proposition de rectification sets out the proposed reassessment, the period covered, the taxes and interest due, and the response window (standard 30 days). The procedural compliance of the reply — each point answered with cross-references to BOFiP paragraphs and the taxes already declared — often decides the issue more than the substantive merits.
• Customs hold on imports. Where the autoliquidation of import VAT has not been correctly recorded, French Customs may apply a hold. We resolve it through a corrective declaration filed with the customs broker.
• Refund delay. 8th and 13th Directive refunds can stall on a missing original invoice or mismatched VAT ID. We re-file with the corrected backup before the statutory cut-off.
• Cessation and B2C threshold breach. Where French operations stop, we file the déclaration de cessation within 30 days. Where an online seller crosses the EU OSS threshold, we outline the route between représentant fiscal, IOSS, and direct OSS depending on trade flow.

The SIEE, French Customs, and the DGFiP central directorate each play a distinct part: registration and routine filings, import VAT and autoliquidation, and audit/dispute/refund files respectively. Where the issue touches personal-income taxes — a non-resident officer earning a French salary, or a beneficiary of a French estate — we coordinate with our private-client tax team.

Benefits of an integrated engagement at Interexco

Bringing the représentant fiscal engagement inside an OEC-regulated chartered accountancy firm produces structural benefits over an unregulated agency offering the same procedural role:

• Single point of contact with indemnity protection. The same partner handles representative work, periodic bookkeeping, statutory reporting, and inspection defence — under the indemnity that French law associates with regulated practice.
• Integrated payroll and social security. Where the foreign group hires French-resident employees, the French payroll, URSSAF and AGIRC-ARRCO contributions, and income tax withholding at source sit alongside the fiscal representation. The PASS (social security ceiling) is €47,100 for 2025.
• Long-term continuity. Over 40 years of practice, we have helped non-resident groups move between mandataire fiscal, représentant fiscal, and French branch or subsidiary as their operations evolve. The continuity of the file across these structural changes is itself a benefit.

Risk management and the firm’s duties

The joint liability of the représentant fiscal is enforceable through standard DGFiP recovery procedures — customs holds on imports, attachment of French bank accounts, and recovery against the firm’s own assets. Our risk management protocol therefore covers:

• Know-your-client. We verify the legal status, beneficial ownership, and operational substance of each foreign group before accepting the engagement.
• Confidentiality. Records on the foreign group’s officers and counterparties are held under the Loi Informatique et Libertés and the GDPR, with CNIL-aligned safeguards.
• Audit trail. We keep a detailed transcript of every DGFiP exchange, every notice received, and every filing made — accessible to the foreign group through our secure client centre. The transcript is a defensive resource if a future audit reaches back several years.

A clean exit from the mandate matters as much as a clean entry: where French operations stop, we file the déclaration de cessation and unwind the registration cleanly. Where the French operations grow beyond the representative model and call for a French entity, we manage the handover.

When a tax representative in France is the right choice

A tax representative in France is the right call when a non-EU firm is selling goods or supplies into the French market, has no French establishment, and operates from a jurisdiction without a mutual-aid arrangement with France. It is also the right option for EU firms (under the lighter mandataire fiscal form) that prefer to outsource the French VAT formalities to a French-regulated firm rather than file returns directly with the DGFiP.

The call turns on three factors: legal necessity (is engagement mandatory under Article 289 A?), operational reach (can the foreign team navigate French filings, French-language correspondence, and French audit complexities in real time?), and strategic horizon (will the French operations grow to a level that justifies a French entity?). For each factor, a regulated, partner-supervised firm reduces the risk and cost of the French VAT footprint.

Frequently asked questions

What is a tax representative in France?

A tax representative in France (représentant fiscal) is a French-established firm appointed by a non-EU business to lodge French VAT returns, manage refund applications, and act as the legally responsible interface with the DGFiP. The representative is jointly liable for the French VAT due. Appointment is mandatory under Article 289 A of the Code général des impôts when the foreign taxpayer is established outside the EU in a jurisdiction with no mutual-assistance agreement with France.

When is appointing a tax representative in France mandatory?

Appointment is mandatory when three conditions are met together: the foreign group is established outside the EU; the country of establishment has no mutual-aid arrangement with France on VAT recovery; and the operator carries out taxable transactions in France. The United Kingdom, Norway, Iceland, and a few other non-EU jurisdictions benefit from mutual-aid covenants and are not subject to mandatory engagement, although they may register through a fiscal agent for operational reasons.

**What is the difference between a représentant fiscal and a mandataire fiscal?

A représentant fiscal is mandatory for non-EU groups without mutual-aid arrangement and is jointly liable for the French VAT. A mandataire fiscal is optional and used by EU-established groups to delegate French VAT formalities; the EU operator retains primary responsibility, with no joint liability on the agent. Operationally the two roles are substantively similar; the legal liability differs.

Can a UK company appoint a fiscal representative in France after Brexit?

The UK benefits from a mutual-aid arrangement with France on VAT recovery, so a UK company is not legally required to appoint a représentant fiscal. UK companies can register for French VAT directly with the DGFiP or appoint a mandataire fiscal on a voluntary basis. In practice, many UK groups select a French fiscal agent for operational reasons — language, deadlines, response to DGFiP inquiries — even where engagement is not mandatory.

What are the penalties for failing to appoint a tax representative in France?

Failure to appoint a mandatory représentant fiscal exposes the foreign group to VAT reassessment, late-filing penalties, and interest on unpaid taxes — enforced through customs holds on imports and DGFiP recovery procedures. The French tax administration treats the non-engagement as a structural failure of the registration rules, not an administrative oversight, and the reassessment can reach back several years.

Does Interexco act as both tax representative and bookkeeping partner for the same client?

Yes. We frequently act as représentant fiscal and as bookkeeping and tax adviser for the same non-resident group, where the foreign operator has French operations significant enough to require both. Combining the two functions inside the same regulated firm avoids the duplication and version-control errors typical when fiscal representation and bookkeeping are kept on separate firms. The integrated scope also reduces cost and shortens the response time on DGFiP queries.

How long does it take to register a foreign group for French VAT through a representative?

The standard timeline from a complete file to issuance of the French VAT number is four to eight weeks, depending on the SIEE workload and the completeness of the supporting documents. We typically request the foreign group’s certificate of incorporation, articles of association, a recent extract of the local commercial register (or the equivalent national record), proof of identity of the signing officers, and a written pouvoir signed by an authorized officer. Files prepared without these documents take longer to process.

How does the September 2026 / September 2027 e-invoicing reform affect a foreign group under engagement?

The French e-invoicing reform requires every taxable person established or VAT-registered in France to connect to a plateforme de dématérialisation partenaire (PDP) for B2B invoice issuance and e-reporting on cross-border flows. Large enterprises must comply from September 2026; SMEs from September 2027. A foreign group under engagement must connect to a PDP through its fiscal representative or through its own billing system; we manage the PDP onboarding as part of the standard engagement.

What does a tax representative in France typically cost?

Fees depend on the volume of operations, the filing frequency, the number of returns to be filed per year (monthly versus quarterly), the complexity of the reverse-charge and intra-EU flows, and the support needed for refund applications. Each engagement is quoted in a written engagement letter with a fixed annual price plus a defined hourly rate for matters outside the standard scope. We provide a tailored quote after a brief intake call with the foreign finance team. Common questions on fees are answered in the proposal itself.

Speak with our French VAT team

If your group carries out taxable operations in France from a non-EU establishment, or if you need a fiscal agent for EU-established operations in France, speak with one of our chartered accountants about your transaction flows, timetable, and registration position.