VAT‑Related Measures in the Approved French Finance Bill for 2026

Below is a structured overview of these VAT‑impacting developments.

1. Strengthening of Digital Reporting Obligations (Indirect VAT Impact)

Although the text does not explicitly modify Article 289 bis CGI (French e‑invoicing rules), the Finance Bill introduces multiple new obligations requiring digital transmission of fiscal information, which extend the administrative architecture also used for VAT reporting.

Key elements:

• Several taxes (e.g., new contributions, exemptions, declarations linked to corporate income and social regimes) now require digital reporting, reinforcing the State’s unified data‑collection frameworks.
• These mechanisms often rely on the same infrastructure used for VAT e‑reporting, thus strengthening the ecosystem where VAT data circulates.

These changes do not directly amend the VAT rules but reinforce the compliance environment for VAT‑related audits and cross‑checks.

2. Adjustments to Tax Bases That Interact with VAT Treatment

The Bill introduces significant new rules governing:

• Real estate amortization schemes (Articles 31, 150 VB and related provisions)
• Enterprise transfers and restructurings
• Asset classifications and exemptions
• Special regimes for rural, agricultural, and local business activities

Although these provisions do not directly change the VAT rate or liability, they alter:

• The taxable base used to compute certain operations also subject to VAT
• The classification of assets that determine whether supplies are taxable or exempt
• The timeline of property development and construction projects, which affects VAT chargeability events

For example, the reintroduction of amortization for new residential rental investments (Article 47) influences VAT deductibility conditions for developers and property‑based operators.

3. New or Modified Excise‑Type Taxes Collected Concurrently with VAT at Import or Sale

Several articles reform energy, vehicle, and environmental taxes. These are not VAT taxes themselves, but they coexist with VAT and are often collected in parallel during import or intra‑EU acquisition:

Examples:

• Revisions to vehicle emissions‑based taxation under the Code des impositions sur les biens et services (CIBS), including:
  • Updated formulas for CO₂‑linked taxation (Article L.421‑20)
  • New mass‑based thresholds
  • Exemptions and abatement rules for hybrid, hydrogen, and electric vehicles (Articles L.421‑66, L.421‑77, L.421‑79, L.421‑79‑1)
• These measures directly affect the import price and VAT calculation base, since VAT on vehicles is computed on the customs and excise‑inclusive value.

Indirect VAT consequence:

A higher (or lower) environmental tax translates into a higher (or lower) VAT amount, because VAT is calculated on “price + all other taxes except VAT”.

4. Reforms to Local Taxes That Influence VAT Treatment of Real Estate and Tourism Operators

The Bill introduces structural changes to local levies that affect VAT‑registered businesses:

Examples:

• Reconfiguration of the taxe de séjour (tourist tax) including explicit addition of taxes additionnelles across multiple code articles (L.2333‑28‑1 and following).
• New rules for gîtes ruraux (Article 55), which affect classification of rentals and therefore VAT liability rules for furnished tourist accommodations.

VAT link:

Tourist rentals can fall under:

• VAT‑exempt regimes,
• Optional VAT regimes (option à la TVA), or
• Mandatory taxable regimes (e.g., para‑hotel services).

Changes in classification alter whether VAT applies.

5. Modifications to Special Economic Zone Rules and Urban Investment Incentives

A substantial portion of the Bill concerns the restructuring of:

• Zones franches urbaines (ZFUs)
• Quartiers prioritaires de la politique de la ville
• Exemptions and incentives for newly created or transferred businesses

(Articles 44 octies B and modifications to 1383 C ter, 1466 A, 1599 quater C).

VAT relevance:

Businesses created in these zones often benefit from special VAT regimes or enhanced deduction rights depending on their turnover, activity, and real estate investments.
Changes to the legal perimeter or status of such establishments modify their VAT obligations and potential waivers.

6. New Structures for Public Infrastructure Pricing (Potential Cross‑Impact on VAT)

Reforms in Articles L.421‑197 to L.421‑224 reorganize:

• Toll structures
• Infrastructure‑use fees
• Pollutant‑based pricing differentials

These charges form part of:

• Transport operators’ cost base,
• Which then forms part of the VAT‑taxable amount for services (freight, logistics, passenger transport).

Thus, even though VAT is not explicitly mentioned, the measures reshape VAT‑inclusive pricing for transport services.

7. Alignment of Tax Concepts and Administrative Definitions Used for VAT Controls

The Bill modernizes several definitions used throughout the tax code:

• “Entité” replacing “société” in Article 1447 (CFE) to reflect broader taxable subjects
• Clarification of depreciation rules, social‑security interactions, and accounting treatments

These adjustments matter because VAT relies heavily on:

• The definition of the “taxable person”
• Accounting continuity
• Asset classification
  All of which are impacted by these definitional changes.

Conclusion

Although the 2026 Finance Bill does not reform the VAT system directly, it introduces a wide set of measures that influence how VAT is calculated, declared, and integrated into business operations. These impacts occur through:

• Changes in other taxes that enter the VAT base
• Adjustments to real estate and construction rules that determine VAT chargeability
• Classification updates for goods, services, and business entities
• Expansion of digital reporting frameworks that reinforce VAT controls
• Reconfiguration of local‑tax regimes affecting VAT‑relevant activities
• Modernization of environmental and transport taxation that indirectly shifts VAT payable amounts

For VAT‑registered businesses, especially those in:

• Real estate and construction
• Tourism
• Transport and logistics
• Automotive and energy sectors
• Entities located in priority urban zones

…this Bill will require careful recalibration of VAT compliance and pricing models in 2026 and beyond.