France Finalises Guidance on the VAT International Agent Regime

Summary 

• France finalised BOFiP guidance on 14 October 2026 for the optional international-agent regime introduced from 1 January 2025 under Article 289 A bis of the General Tax Code. 

• The regime can cover specified imports, exports and transactions involving goods leaving customs or VAT-suspension arrangements, but excludes intra-Community acquisitions and certain supplies of imported goods. 

• The French agent receives a specific VAT number, files a separate return for eligible transactions and is jointly and severally liable for related VAT, interest and penalties. 

Extended article 

The international-agent regime offers an alternative to ordinary fiscal representation for a foreign taxable person that is neither established nor VAT-registered in France. The agent must be established and VAT-registered in France, satisfy tax-compliance conditions and hold the goods under an eligible contractual arrangement, such as consignment, processing, assembly, manufacturing, rental, warehousing or transit. 

The mandate must be concluded before the relevant transactions and specify its duration, the arrangements under which the goods are entrusted and the transaction categories covered. Only input VAT linked to transactions eligible for this regime may be deducted through the agent’s separate VAT return. Businesses should therefore ring-fence the relevant flows and supporting records. 

Source 

• French Tax Administration: BOI-TVA-DECLA-20-30-40-30 

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