France – New tax representative regime for imports 2025: companies and operations concerned

Discover which businesses and operations are affected by the new import fiscal mandate regime. Conditions, accreditation procedures, and reporting obligations: everything you need to know to secure your imports and optimise VAT management.

Companies and operations concerned by the new import fiscal mandate regime

The new import fiscal mandate regime is established by Article 289A bis of the CGI.

Concerned companies

The new import fiscal mandate applies to companies that cumulatively meet the following conditions:

The company carries out an economic activity that grants it the status of a taxable person
The company is not established in France
The company does not have a VAT number in France

Concerned operations

This regime applies to the aforementioned companies when the only operations subject to VAT in France that they carry out are as follows:

Imports for which VAT is fully deductible
Other operations, determined by decree.

This decree No. 2025-153 was published on 18 February 2025 and inserts a new Article 95 ter into Annex III of the CGI.

This article defines the operations eligible for the import fiscal representative mechanism. In addition to imports subject to VAT with a right to full VAT deduction, it also applies to the following non-taxed operations:

Exports and assimilated operations (in accordance with Article 262 of the CGI).
Operations carried out under suspensive customs and tax regimes, resulting in the export of goods.
Imports that have been subject to one or more deliveries under these same suspensive customs and tax regimes.

"Warning – although the regime of occasional fiscal representation has disappeared as of 1 January 2025, the import fiscal mandate regime cannot apply to imports under regime 42 carried out by non-European companies on French territory. Indeed, this provision does not cover exempt imports, nor exempt intra-community deliveries."

How to appoint a tax representative for importation?

Conditions relating to the Tax Representative for Importation

The tax representative for importation must be identified as such by the tax authority to which they are subject; to do this, the following conditions must be met:

They must be established and registered for VAT in France for at least one year.
Their directors must not have committed any serious or repeated tax offences and must not have been sanctioned under articles L. 651-2, L. 653-2, and L. 653-8 of the Commercial Code in the last three years and must not be subject to any ongoing prohibition.
They must have submitted monthly or quarterly VAT returns in their own name and on their own account.
They must have a written mandate from the taxable person specifying the period of application and the conditions under which the principal entrusts their goods in France.
They must be entrusted with the goods under a consignment sale, processing, assembly, manufacturing, leasing, or storage contract, or a contract ensuring the transit of goods to a territory other than France.

Procedure for accrediting the tax representative for importation

To obtain a specific identification number, the tax representative for importation must be accredited by the tax authority to which they belong.

To do this, they must submit a request including:

Their name or business name, address, and their own individual identification number;
The name or business name, postal and electronic address, and identification number in their country of each taxable person who has appointed them as a representative;
A copy of the mandate from their principal;
A sworn statement that they meet the tax requirements.

Important! For each new principal, the representative must provide the administration with the relevant information before submitting the first declaration including the principal's operations.

Management of reporting obligations by the tax representative for importation

The tax representative for importation electronically submits the VAT declaration covering all operations declared in the name and on behalf of their principals.

They must also maintain a register that records for each appointed taxable person the following information regarding the declared operations:

The date of delivery of the goods or their importation
The amount of the taxable base
Any subsequent increase or reduction of the taxable base
The rate and amount of VAT
Where applicable, the article relating to the exemption/dispensation or suspension applied
The amount and date of any deposit received before the delivery of the goods.

The representative must keep the records until 31 December of year N+3 and provide them to the tax administration upon request within 20 days.

The import fiscal mandate: a new VAT solution for imports by French contractors on behalf of non-European clients

The import fiscal mandate provides a solution for French contractors who import goods on behalf of non-European clients and cannot, in principle, deduct the VAT on imports. By allowing them to declare and deduct the VAT on imports on behalf of their non-European client, this mechanism reduces financial costs and secures operations from a VAT perspective. It is an effective alternative to setting up an active processing scheme, a suspensive tax regime, or VAT registration.

Discover in detail the procedures for setting up the import tax mandate for contractors by reading our dedicated article

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