E-reporting for foreign companies without a permanent establishment in France

10 novembre 2025 Lecture 6 minutes

Transaction and payment data declaration applicable to foreign companies without a permanent establishment in France.

The electronic invoicing (e-invoicing) provided for in Article 289 bis of the French General Tax Code (CGI) covers all transactions of purchases and sales of goods and/or supplies of services carried out in France between VAT-taxable persons established in France (see the section “E-invoicing – an overview”, in French only).
Therefore, e-invoicing does not apply to foreign companies that do not have a permanent establishment in France. 
However, there are e-reporting requirements for foreign companies not established in France that carry out transactions considered to take place in France, for which they are liable to French VAT under CGI rules. 
E-reporting is the transmission to the tax authorities of certain information (e.g. the amount of a transaction, the amount of VAT charged, etc.) relating to commercial transactions not covered by e-invoicing.

What data must be e-reported to the tax authorities ? 
 

As a general rule, the company carrying out the transaction must e-report certain transaction data as listed by decree (list of transaction data; list of payment data – in French only).
Unlike with the e-invoicing system, invoice data is not reported in the normal course of business or on a daily basis, but rather at intervals set based on the company’s VAT arrangements. For more information, go to Frequencies and deadlines for reporting transaction and payment data (in French only). 

There are two e-reporting components – transaction data and payment data:


   • Transaction data (Article 290 of the CGI)


     - International B2B:
The data to be e-reported is the same as that transmitted as part of the e-invoicing procedure, except the SIREN number of the company not established in France. Where necessary, the intra-Community VAT number or the foreign tax identification number will be provided instead of the SIREN number. 
The foreign companies subject to e-reporting requirements are set out in Article 290(II) of the CGI. These are in particular companies not established in France that carry out transactions from France with another taxable person not established in France (exports, intra-Community supplies, sales or services considered to take place in France and subject to VAT).
N.B:
The taxable seller or service provider not established in France is liable to VAT on the supply of goods or services referred to in Article 259 A of the CGI when the buyer of the goods or services does not have a French VAT identification number. Consequently, the seller/service provider is subject to e-reporting requirements.
However, a foreign company not established in France is not liable to VAT in France if its customer is a French or foreign company established or not established in France and identified for VAT in France. In that case, it is the buyer of the goods being purchased or service(s) being provided in France who is subject to e-reporting requirements (VAT reverse charge transactions).   
Likewise, intra-Community purchases made by a taxable person not established in France must also be e-reported.
However, the date on which e-reporting requirements for reverse charge transactions and intra-Community purchases will be effective has been postponed to 1 September 2027. 
The following are excluded from e-reporting:
- transactions that are exempt from VAT under the provisions of Articles 261 to 261 E of the CGI, and exempt from invoicing. This is the case, for example, with certain banking and insurance transactions, medical and health services, educational services and transactions carried out by non-profit organisations run on a non-lucrative basis;
- transactions resulting in a defence or security contract within the meaning of the French Public Procurement Code; 
- transactions carried out subject to a classification measure within the meaning of Article 413-9 of the French Criminal Code or covered by a confidentiality clause provided for on grounds of national security by a contract for works, supplies and services or the supply of equipment referred to in Article L.1113-1, 1° to 4° of the French Public Procurement Code;
- imports of goods.

     - International B2C:
The data to be e-reported concerns aggregate VAT-liable transactions per day, which the tax authorities can use to calculate the value of the company’s transactions net of VAT, broken down according to VAT rate and the corresponding VAT amount. 
Such transactions include sales and supplies of services in connection with a non-taxable person (e.g. retail with individuals) where a transaction is liable to French VAT under CGI rules. 
Exception: Transactions with a non-taxable person if the operator not established in France is registered with an EU VAT One Stop Shop.


   • Payment data (Article 290 A of the CGI)


This covers collection data, i.e. the collection date, the amount collected inclusive of VAT, broken down according to VAT rate, where applicable, and the invoice number where necessary.
Payment data is reported by the entity that receives the payment (issuer of the invoice), 
These transactions are referred to in Articles 289 bis and 290 of the CGI when they relate to supplies of services, if no option is available for the payment of VAT on debits. 
This component of the reform applies to all types of customer, regardless of whether they are established in France or abroad, or whether they are professionals or non-taxable persons.

 

E-reporting implementation schedule

 

Note: Foreign companies not established in France will not be subject to e-invoicing requirements (receiving and issuing e-invoices).  
Sharing the same schedule as that for companies established in France, foreign companies will only be subject to e-reporting requirements (transaction and payment data reporting):
   • as of 1 September 2026 for large companies and intermediate-sized enterprises (ISEs);
   • as of 1 September 2027 for micro-enterprises and small- and medium-sized enterprises (SMEs).
     
    > Notes on the schedule:


   • The transition to e-invoicing may be brought forward by micro-enterprises and small- and medium-sized enterprises to starting from 1 September 2026;
   • For foreign companies not established in France, e-reporting requirements may be postponed to as of 1 September 2027 for reverse charge and intra-Community transactions.


    > Notes on the different categories of company:


   • A micro-enterprise is a company employing fewer than ten people and with annual turnover or balance sheet total below €2 million;
   • An SME is a company employing fewer than 250 people and with annual turnover not exceeding €50 million or a balance sheet total not exceeding €43 million;
   • An ISE is a company outside the SME category, employing fewer than 5,000 people and with annual turnover not exceeding €1,500 million or a balance sheet total not exceeding €2,000 million;
   • A large company is one that cannot be classified in any of the above categories: employing more than 5,000 people, or, if the figure is below that, a turnover of greater than €1,500 million and a balance sheet total exceeding €2,000 million.
     
Company size is assessed as at 1 January 2025, based on the last financial year ended before this date or, if the entity did not carry out business in that year, on the first financial year ended as from this date.
A company moves up to the next category:
   • when the workforce criterion is exceeded;
   • in the event that the workforce condition is not met, only if the annual turnover and balance sheet total are above the threshold.
The concept of a company is that of a legal unit, since a legal unit can be identified by its SIREN number.
For reporting requirements relating to the turnover threshold, overall turnover (generated in France and abroad) is taken into account.

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