E-Reporting for Foreign Companies Without a Fixed Establishment in France

E-Reporting for Foreign Companies Without a Fixed Establishment in France

Foreign companies without a fixed establishment in France are not subject to the einvoicing part of the reform, which only applies to transactions between taxable persons established in France.

However, they may be subject to ereporting if they carry out transactions deemed to take place in France for which French VAT is due. Transaction data and, in some cases, payment data must be reported to the French tax authorities.

The obligation applies:

  • from 1 September 2026 for large companies and medium-sized enterprises (ETIs) acting as sellers or service providers
  • from 1 September 2027 for micro, small and medium-sized enterprises
  • from 1 September 2027, regardless of company size, for intra‑EU acquisitions and reverse‑charge transactions.
  • Company size is assessed on 1 January 2025 based on the latest closed financial year and worldwide turnover.

 

Company-size thresholds

micro/small business < 10 employees and (turnover ≤ €2m or balance sheet ≤ €2m)

SME < 250 employees and (turnover ≤ €50m or balance sheet ≤ €43m)

ETI < 5,000 employees and (turnover ≤ €1.5bn or balance sheet ≤ €2bn)

large company ≥ 5,000 employees or, below that threshold, turnover > €1.5bn and balance sheet > €2bn.

 

Micro, small and medium-sized enterprises may voluntarily start e-reporting from 1 September 2026.

 

Scope

E‑reporting applies in particular to:

  • taxable supplies of goods and services in France by non‑established businesses
  • taxable intra‑EU acquisitions in France
  • certain reverse‑charge transactions
  • certain B2C transactions subject to French VAT.

Exports, intra‑EU supplies, imports and VAT‑exempt transactions are excluded.

Where the foreign company is liable for French VAT, it must submit e‑reporting. If the customer is VAT‑registered in France and the reverse‑charge mechanism applies, the obligation shifts to the customer. The reported data are generally the same as for e‑invoicing, except that the SIREN may be replaced by a foreign VAT number or another foreign identification number.

 

Payment eReporting

Payment e‑reporting applies to services and advance payments for goods where VAT becomes due upon receipt of payment. Reverse‑charge transactions and invoice‑based VAT are excluded. The report includes the payment date, VAT‑inclusive amount by VAT rate and, where applicable, the invoice number. It is submitted by the invoice issuer.

 

Procedure

Data is submitted at intervals that depend on the company’s VAT regime. The companies concerned must, before their obligations come into force, choose an approved platform (see list) responsible for submitting the information to the tax authorities.

Frequency and deadlines for submitting transaction and payment data (e‑reporting)

How to determine whether your company is affected

 

1. Is the company VATregistered in France?

No = No obligation

Yes = Review the transactions carried out

 

2. Does the company make supplies of goods or services for which French VAT is due?

Yes = Ereporting applies

  • Large companies / ETIs: from 1 September 2026
  • SMEs / small businesses / micro‑enterprises: from 1 September 2027

 

The obligation includes transaction reporting and, where applicable, payment reporting

No = Check intraEU acquisitions and reversecharge transactions.

3.Does the company make intraEU acquisitions or reversecharge transactions in France?

Yes = Transaction ereporting from 1 September 2027 regardless of company size.

No = No obligation

 

A foreign company without a permanent establishment in France is subject to e-reporting only if it is registered for VAT in France and carries out transactions falling within the scope of the reform. The date on which the reform comes into force depends on the nature of the transactions carried out and, for transactions as a seller or service provider, on the size of the company.

If you have further questions, our accountants will be happy to provide you with personal advisory. Additionally, we are available to advise you throughout France and Germany by phone and video conference. Your Franco-German tax consultancy FRADECO.

Disclaimer


Although the greatest possible care has been taken in the preparation of this newsletter, we reserve the right to make changes, errors, and omissions. The abstract legal presentation in this newsletter is no substitute for individual civil and tax law advice on a case-by-case basis. Subsequent changes to the legal framework, the views of the German or French tax authorities or case law, including with retrospective effect, are possible.