France Transfers VAT rules into new Consolidated Tax Code

Starting on 1st September 2026, France will officially transfer its Value Added Tax (VAT) provisions from the General Tax Code (Code général des impôts or CGI) to a dedicated section within the new Goods and Services Tax Code (CIBS — Code des impositions sur les biens et services). This move represents a fundamental structural reorganisation of French indirect tax law.

What is Changing?
While the reform is primarily a recodification rather than a change in tax policy, it involves a substantial remodelling of how VAT rules are presented.

– The CIBS will now serve as the single home for all indirect taxes, grouping VAT in Book II alongside excise duties and other sector-specific taxes.

– VAT provisions are being restructured by business sector to make the code more intuitive for specific industries.

– Long-standing principles from the Court of Justice of the European Union (CJEU) are being formally written into the statute, including concepts like the “fixed establishment” and the “direct link” test for consideration.

– The new code introduces refreshed legal terms and formalises concepts such as the “zero rate” (0%).

– The reform incorporates mandatory elements of the ViDA (VAT in the Digital Age) package and updates for distance sales.

Impact on E-Invoicing Reforms
It is critical for businesses to note that this recodification is separate from France’s major e-invoicing mandate. Starting from September 2026, all French businesses must be able to receive e-invoices, while large and mid-sized companies must begin issuing them.

For now, the e-invoicing provisions will remain in the CGI and will only be integrated into the CIBS at a later, which is not yet specified.

Transition Timeline for Businesses
The French government has introduced “tolerance measures” to allow for a smooth adjustment period.

Effective Date: 1 September 2026.

Tolerance Period: Businesses may continue to use former CGI article references on invoices, contracts, and other legal documents until 31st December 2027.

Administrative Guidance: Existing tax rulings and guidance remain valid even if they still refer to the old CGI numbering.

Preparation Checklist
To ensure compliance before the September 2026 deadline, organisations should:

  • Update ERP Systems: Identify and map old CGI references to new CIBS articles using official concordance tables.
  • Review Templates: Plan updates for invoice templates, general terms and conditions, and legal contracts.
  • Coordinate with E-Invoicing: Align the recodification updates with the implementation of the new e-invoicing and e-reporting workflows.