France Finalises Guidance on Transition to the Recodified VAT Code

Summary 

• The French tax authorities finalised BOI-RES-TVA-000253 on the transfer of VAT legislation from the CGI to the CIBS. 

• The recodification is scheduled to take effect on 1 January 2027 and is generally intended not to alter the substantive VAT rules. 

• Existing administrative doctrine and rulings based on the former provisions remain enforceable, subject to the qualifications in the guidance. 

Extended article 

On 7 October 2026, the French tax authorities finalised their guidance on transferring VAT provisions from the Code général des impôts to the Code des impositions sur les biens et services. The guidance is published as BOI-RES-TVA-000253. The recodification, initially scheduled for September 2026, is expected to apply from 1 January 2027. 

The guidance explains that the recodification is primarily intended to improve the organisation and clarity of the legislation. As a general rule, it does not change the existing VAT treatment. Administrative doctrine and individual rulings based on the former CGI provisions remain enforceable against the tax authorities. Exceptions may arise where the recodified text incorporates EU Court case law or makes a specifically identified adjustment. Businesses should map old and new legal references in invoices, contracts, exemption certificates, opinions, tax engines and compliance manuals using the official glossary and concordance tables. 

Exact sources 

• French Tax Administration, BOI-RES-TVA-000253 

• French Tax Administration BOFiP portal 

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