France Clarifies VAT Treatment for Dropshipping Outside IOSS: BOFiP Rescript of 4 March 2026

Summary

• Clear TVA framework for dropshipping outside IOSS: The French tax authorities clarify how VAT must be declared and paid for distance sales of imported goods (VAD‑BI) when the seller does not use the Import One Stop Shop (IOSS), depending on the logistics flow and value of the goods. [bofip.impots.gouv.fr]
• Import VAT redevability depends on value and destination: For goods imported via France and shipped to another EU Member State, France is not the place of taxation for the sale, but import VAT rules differ for consignments below or above €150. [bofip.impots.gouv.fr]
• Seller may become fully VAT‑liable in France: Where the import VAT base differs from the sales price, or for certain sales to French customers, the seller becomes liable for both import VAT and French VAT, triggering registration and compliance obligations. [bofip.impots.gouv.fr]

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Article – BOFiP Rescript BOI‑RES‑TVA‑000184 (4 March 2026)

Background and scope

In a rescript published on 4 March 2026, the French tax administration issued detailed guidance on the VAT treatment of distance sales of imported goods (VAD‑BI) carried out via a seller’s own website—commonly referred to as dropshipping—where the seller has not opted for the Import One Stop Shop (IOSS). The guidance applies regardless of where the seller is established and focuses on B2C sales to customers in France or other EU Member States. [bofip.impots.gouv.fr]

The rescript responds to practical uncertainty around VAT declaration, payment, and redevability, particularly in cross‑border logistics chains involving third‑country suppliers.

Goods imported into France and shipped to another EU Member State

Where goods are imported into the EU via France but subsequently delivered to customers located in another EU Member State, the place of supply for VAT purposes is the Member State of destination, in line with Article 33 of the VAT Directive. France is therefore not the place of taxation of the distance sale itself. [bofip.impots.gouv.fr]

However, the VAT treatment of the importation into France depends on the intrinsic value of the consignment:

• Consignments below €150:
  If the seller was eligible for IOSS but did not opt for it, the goods cannot be cleared for free circulation in France. Import clearance must occur in the Member State of final destination, and France can only be used as a transit country under the external transit procedure. No French import VAT is due. [bofip.impots.gouv.fr]
• Consignments above €150:
  The seller is redevable for French import VAT when the goods are imported into France. That import VAT is deductible, provided it relates to a taxable distance sale in another EU Member State. [bofip.impots.gouv.fr]

Goods imported into France and delivered to French customers

For goods imported into France and sold to customers located in France, the rescript distinguishes two key scenarios.

Import VAT payable by the customer

The customer is liable for import VAT where all of the following conditions are met:

• the goods arrive in France,
• the sale is not facilitated by an electronic interface,
• the seller has not opted for IOSS, and
• the import VAT base is identical to the sales price.

In this case, the seller is not liable for import VAT and the distance sale is not subject to EU VAT. [bofip.impots.gouv.fr]

Import VAT and sales VAT payable by the seller

If the import VAT base differs from the sales price, the seller becomes:

• liable for French import VAT, and
• liable for French VAT on the distance sale, which is deemed to take place in France.

This triggers a full set of VAT obligations, including French VAT registration, customs formalities, VAT reporting, and collection. Import VAT remains deductible under normal rules. [bofip.impots.gouv.fr]

Compliance implications for non‑EU sellers

The rescript confirms that non‑EU sellers required to register and comply with French VAT obligations must appoint a fiscal representative in France, unless they are established in a country benefiting from equivalent mutual assistance arrangements. [bofip.impots.gouv.fr]

Key takeaway

This rescript significantly raises the VAT risk profile of non‑IOSS dropshipping models, particularly where pricing structures or logistics flows result in different import and sales values. Businesses operating cross‑border e‑commerce models involving France should reassess their VAT position, registration strategy, and use of IOSS to avoid unintended VAT liabilities. [bofip.impots.gouv.fr]

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