France – End of one-off fiscal representation for imports: Extension granted

Background

Non-EU businesses that are liable to VAT register in France must appoint a fiscal representative.
However, if a business is based in one of the countries with which France has concluded a tax mutual assistance agreement, a fiscal representative is not required.

French law also allows taxable persons not established in the EU who carry out only certain transactions (such as import followed by intra-community supply) to appoint a taxable person established in France, to carry out the reporting obligations, this is known as one-off fiscal representation. This mechanism could be used for instance by companies established in a third country that has not signed a tax mutual assistance agreement with France.

In parallel, French law introduced as of January 1, 2025, the possibility for all foreign companies not established and not VAT registered in France to use an import agent responsible for carrying out all or part of their tax and payment formalities on their behalf, without having to VAT register  themselves or appoint a fiscal representative in France, as the case may be, when they carry out only certain transactions in the context of international trade (such as imports).

As of the same date, the one-off fiscal representation mechanism, has been abolished when taxpayers carry out only certain transactions for which they are exempted from paying VAT.

What’s new for VAT registered businesses?

On May 14, 2025, the French tax authorities have granted an exceptional extension to the one-off fiscal representation scheme until December 31, 2025. This will allow taxable persons established outside the EU the time they need to set up the mandate required under the import agent scheme, or to complete the VAT registration formalities.

The VAT registration numbers of one-off fiscal representatives of the taxpayers concerned therefore remain valid until this date.

What should you do?

Companies established in non-EU countries which have not signed an agreement with France, and which are concerned by the abolition of the one-off fiscal representation, may decide to use one or more import agents if they only carry out imports for which VAT is fully deductible, and certain transactions involving goods in the context of trade with non-EU countries. If this is not the case, they must appoint a fiscal representative and obtain a VAT identification number in France.

Please also keep in mind that while companies located outside the EU which are removing goods from customs or tax warehouse regimes, or performing imports followed by exempt intra-Community deliveries, were able to avail of the one-off fiscal representative before December 31, 2024. However, they must now appoint a fiscal representative due to the fact that this category of operations does not fall within the scope of the import agent any longer.

We encourage businesses to review the above rules to assess how it can impact their VAT registration in France.

Should you wish to obtain more details, please contact us.