New VAT recodification in France: unchanged law, perhaps… unchanged reasoning, not quite

As of September 1, 2026, VAT provisions will transition from the French General Tax Code to the Code of Taxes on Goods and Services, aiming to improve the readability and structure of VAT law while maintaining its economic substance and tax burden.
The recodification introduces a new analytical framework for VAT concepts like the right to deduct and exemptions, requiring businesses and practitioners to adapt their understanding and application of VAT rules, even if the fundamental principles remain unchanged.
The reform emphasizes the need for clarity and legal certainty, incorporating CJEU case law directly into statute, while also highlighting the importance of aligning the CIBS implementation timeline with secondary legislation to ensure a smooth transition for taxpayers and tax authorities.