Control of the Single VAT Taxable Person Regime

As provided in Article 11 of Council Directive 2006/112/EC of November 28, 2006, regarding the common system of value-added tax (VAT), the “single taxable person” arrangement allows each European Union Member State to treat as a single taxable person those individuals established within their territory who, while legally independent, are closely connected financially, economically, and organizationally.

This arrangement, incorporated into domestic law under Article 256 C of the General Tax Code (CGI), undergoes certain adaptations concerning control rules.

In accordance with Article L. 16 F of the Tax Procedure Book (LPF), members of a single taxable person entity formed under Article 256 C of the CGI may be subject to audits as if they were not members of the single taxable person, with the exception of deliveries and services to another member of this single taxable person.

Furthermore, the 5° bis of Article L. 51 of the LPF also provides exceptions to the prohibition on repeating an accounting verification or examination within the framework of the single taxable person regime.

Additionally, under Article L. 66 A of the LPF, a member of a single taxable person may be subject to value-added tax (VAT) assessment under specific conditions.

Source: bofip.impots.gouv.fr

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