e-reporting for foreign VAT-registered businesses without Permanent Establishment
France’s e-invoicing reform begins on 1 September 2026 for French resident businesses, but the impact extends to non-residents with a local VAT number.
Foreign businesses registered for French VAT but without a permanent establishment in France also fall within the digital French e-reporting regime but with a complex 1-year phase-in process.
French e-reporting phased on based on size of tax payer and type of transaction
Determining if a non-resident is subject to e-reporting, and which transactions to report is complex between the phased introduction Sept 2026 to Sept 2027. There are separate criteria:
1. Phased by size of taxpayer
A non-resident business falls into this first wave only if it is a ‘Large Enterprise’, meeting at least two of the following thresholds:
-
- Employees : > 250
- Turnover : > €50 million
- Balance sheet : > €43 million
These thresholds must be assessed on a worldwide basis, not by looking only at French turnover or French transactions.
Smaller non-resident businesses benefit from a one-year deferral. From 1 September 2027, the obligation extends to all businesses, including smaller non-resident VAT registrations.
2. Phased by transaction scope
The French rules also phase in the mandate by limiting which transactions must be reported in the first year:
1 Sept 2026: in-scope non-resident businesses only have to e-report transactions on which French VAT is actually collected.
1 Sept 2027: the scope expands to include other transactions where VAT is due in France even if collected through different mechanisms. This wider scope includes:
- intra-Community acquisitions of goods;
- transactions subject to the reverse charge; and
- more generally, supplies falling under reverse charge Articles 194 and 199 of the VAT Directive
Accredited platform required for non-residents’ e-reporting
A key clarification from the French Tax Office for Non-Residents (DINR) is that non-resident companies must still use an accredited platform to transmit e-reporting data.
Even though these companies do not issue French e-invoices, they must connect to the reporting system through an accredited platform before their go-live date.
Importantly, registration in the system directory does not create an obligation to issue or receive French e-invoices for non-resident businesses.
The French e-invoicing pilot started in February, and will continue till the September 2026 launch.
e-reporting data
Although e-invoices themselves are not required for non-resident companies, the transactional data must still be transmitted to the tax authorities via e-reporting.
Typical data elements include:
- Identification of supplier and customer
- Transaction or invoice number and date
- Net and gross amounts
- VAT rates and VAT amounts
- Whether the supply concerns goods or services
- Payment data where VAT becomes chargeable upon payment (for example services or advance payments)
For B2C transactions, data is generally reported in aggregated form per day and per VAT rate.
Frequent reporting deadlines
France is introducing a high-frequency reporting cadence For businesses under the normal French VAT regime, transactions must be reported three times per month:
- By the 10th: transactions from the 1st to the 10th
- By the 20th: transactions from the 11th to the 20th
- By month-end: transactions from the 21st to the end of the month
Businesses under simplified VAT regimes may instead report monthly within seven days of month-end.
Corrections are permitted, but amended reports must reference the original transmission code.
