The French Supreme Court reaffirmed that contractual arrangements determine the recipient of services for VAT purposes in the American Express case. It ruled that issuer commissions are considered services supplied to a non‑EU recipient, allowing the French entity to recover VAT on those commissions. The decision reinforces the importance of economic substance and contractual reality in VAT treatment.
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Melasoft · 28 days ago
France will enforce e-invoicing for B2B transactions from 1 September 2026, requiring all VAT‑registered businesses to receive and issue invoices in UBL, CII, or Factur‑X formats via certified dematerialisation platforms. The obligation extends to SMEs and micro‑businesses on 1 September 2027, and the Business Directory based on SIREN numbers will replace email addresses for recipient identification.
E-Invoice.app · about 1 month ago
The blog explains that ISO 27001 certification is becoming a mandatory requirement for e‑invoicing platforms in several jurisdictions, notably France, the Netherlands, Australia, and New Zealand. It outlines the key dates, such as France’s September 2026 deadline and the October 2025 completion of the ISO 27001:2022 transition, and details the certification’s three‑year validity and surveillance audit schedule.
Fonoa · about 2 months ago
The French e-reporting framework complements e-invoicing by capturing B2C, cross-border B2B and certain payment transactions through Flow 10 (F10). Flow 6 (F6) confirms acceptance or rejection of the reporting file. Reporting frequency and deadlines vary by VAT regime, with standard monthly taxpayers submitting transaction data three times a month and payment data once, all due 10 days after each period.
VATabout · about 2 months ago
The French Tax Authority issued guidance on March 4, 2026 clarifying VAT obligations for dropshipping operations that do not use the IOSS. The guidance sets thresholds for import VAT liability, specifies when the seller or consumer is responsible, and requires non‑EU sellers to appoint a tax representative. It also defines the place of taxation for cross‑border distance sales.
VatCalc · 2 months ago
France’s 2026 Finance Law introduces stricter penalties for non‑compliance with the upcoming e‑invoicing and e‑reporting regime, effective from 1 September 2026. The law sets €50 fines per non‑approved invoice, progressive penalties for failing to receive e‑invoices, and €500 per missing e‑reporting transmission, capped at €15,000 annually. A first‑offence tolerance allows penalty waivers if errors are corrected within 30 days.
VatCalc · 2 months ago
France has issued guidance clarifying VAT obligations for dropshippers who do not use the IOSS scheme. The ruling specifies that parcels below €150 are cleared in the final destination Member State and the seller is not liable for French VAT, while parcels above €150 trigger import VAT liability in France. It also outlines conditions under which the customer or seller bears import VAT when goods are delivered within France and requires non‑EU sellers to register and possibly appoint a French tax representative.
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Key Takeaways
It ruled that issuer commissions are considered consideration for services supplied to a non‑EU recipient, allowing the French entity to recover VAT on those commissions.
By treating issuer commissions as services to a non‑EU recipient, the ruling enables French entities to claim VAT deductions on those commissions, improving their VAT recovery ratio.
The Court relied on the principle that contractual terms must reflect the economic and commercial reality of the transaction, citing the CJEU Paul Newey judgment.
The improved VAT recovery from treating commissions as services to a non‑EU recipient can enhance the salaries tax position, as the tax depends on the proportion of turnover that allows VAT deduction.
Primary source
Read the full article at Bloomberg TaxThis summary was published on VATfaqs.com on 12 May 2026. It relates to VAT developments in France. The original source is Bloomberg Tax.
