French VAT registration for foreign companies: when you must register and how CA3 filing works

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Files French CA3 returns and German VAT returns for foreign sellers

Vaytax is operated by FRADECO GmbH tax advisory firm, a Franco-German tax advisory firm specialising in cross-border VAT compliance for international businesses. The firm holds both German tax advisor and French Expert-Comptable qualifications and files French VAT returns for foreign companies.

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You are a foreign online seller, your goods are about to sit in a French warehouse, and you are trying to work out whether France now wants a VAT number from you. The short answer is yes: the moment stock is held in France, or goods are imported into France, or supplies are made from French stock, a company established outside France has a French VAT registration obligation, and it applies from the first transaction with no threshold. This guide explains the triggers in plain terms, when a fiscal representative is required and when it is not, how the monthly CA3 return works, how France handles import VAT differently from most countries, and where the OSS scheme does and does not help.

When does a foreign company have to register for VAT in France?

A company established outside France must hold a French VAT number before it makes its first taxable transaction in France. For an e-commerce seller, four situations are the common triggers:

• Holding or storing stock in France. The instant your goods are stored on French soil, including in an Amazon fulfilment centre in France under Pan-EU FBA, you are treated as making supplies from France and must be registered. There is no minimum quantity and no grace period: one pallet in a French warehouse is enough.
• Importing goods into France. If you bring goods into France from outside the EU and clear them there, you need a French VAT number to account for the import (see the import-VAT section below).
• Domestic supplies from French stock. Selling to French customers out of stock that is already in France is a domestic French supply, which requires French VAT to be charged and reported locally.
• B2C distance sales without OSS. Selling B2C into France from another EU country counts toward the EU-wide 10,000 euro distance-sales threshold. Above it, you either report through the Union OSS from your home country or register in France. This is the one trigger OSS can absorb, and only when you hold no stock in France.

The distinction that catches most sellers is between where the customer is and where the stock is. Selling to French consumers from stock held elsewhere can often run through OSS. Selling from stock that physically sits in France cannot: that always needs a French registration, whoever the customer is.

Does a foreign company need a fiscal representative in France?

This is the question that decides whether registration is straightforward or blocked, and the answer turns on where your company is established, not on what or how much you sell.

• Established in the EU: no fiscal representative is required. You register directly, and you may appoint an agent (mandataire) to handle the paperwork while you remain the sole party liable for the VAT.
• Established outside the EU: it depends on a published list. France maintains a list, set by the arrêté of 15 April 2021, of non-EU countries that have a mutual-assistance agreement with France on VAT recovery. Companies from a listed country are exempt and can register without a representative. The United Kingdom is on that list, so a UK company registers in France much like an EU one.
• Established in a non-listed country: a company from a country not on the list, for example the United States, China, Hong Kong, Switzerland or Israel, must appoint an accredited représentant fiscal in France. That representative becomes jointly and severally liable for the company's French VAT, which is why the role is only taken by a France-established entity willing to carry that liability.

What is the CA3 return, and when is it due?

A foreign company registered in France sits under the régime réel normal, and its VAT return is the CA3 (Formulaire 3310-CA3). Three things about it surprise sellers coming from other countries:

• It is monthly. The CA3 is filed every month, electronically, through the espace professionnel on impots.gouv.fr. It is due around the 19th of the month following the reporting period, and around the 24th in months where you declare import VAT.
• Nil months still file. A month with no sales still requires a return, filed as a nil (néant) declaration. Skipping it is a filing failure, not a saving.
• There is no annual return. Under the régime réel normal France has no year-end VAT reconciliation. This is a genuine difference from Germany, where a monthly filer also files an annual Umsatzsteuererklärung after year-end. In France, the twelve monthly CA3 returns are the whole obligation.

Payment works by direct debit: the French tax administration pulls the VAT due by SEPA on the strength of a mandate lodged with your bank, with a wire transfer as the acknowledged fallback where a bank will not support the mandate.

How does France handle import VAT?

France runs one of the more seller-friendly import-VAT systems in the EU, and it is worth understanding before you assume France will cost more than a border-payment country. Since 1 January 2022, import VAT is reverse-charged automatically on the CA3 return rather than paid to customs at the border. If you hold a French VAT number, the import VAT you owe is pre-filled on your return, usually available around the 14th of the month, and you both declare and deduct it on the same CA3.

For a fully taxable business the practical effect is that import VAT becomes a wash rather than a cash outlay: you no longer pay it upfront at the border and wait to recover it later. That removes the working-capital drag that catches sellers in countries where import VAT is paid on entry and reclaimed months afterwards. It is one of the concrete reasons a French registration is less painful than its reputation, once it is in place.

Does OSS remove the need to register for VAT in France?

Only for one flow. The Union One-Stop-Shop lets you declare cross-border B2C sales into France, and into other EU countries, from a single OSS return filed in your home member state, once your EU-wide distance sales pass the 10,000 euro threshold. For a seller shipping to French consumers from stock held elsewhere, OSS can indeed replace a French registration.

What OSS does not cover is anything that involves goods physically in France: holding stock in France, importing into France, and domestic supplies from French stock all require a local French VAT registration, OSS or not. This is the trap for Pan-EU FBA sellers. If Amazon moves your inventory into a French fulfilment centre, you have stock in France, and no amount of OSS reporting substitutes for the French VAT number that stock creates. The two schemes coexist: OSS for the cross-border B2C leg, a local French registration for everything anchored to French stock.

Registering in France and Germany at the same time

Many sellers who reach France do so because Amazon Pan-EU FBA has spread their stock across several countries at once, and Germany and France are the two largest. The two registrations are separate procedures with separate authorities: in Germany the local Finanzamt (routed by your country of establishment), in France the Service des impôts des entreprises étrangères (SIEE), the single office in Noisy-le-Grand that handles every foreign company's French VAT. French registration is applied for through the national business-formalities portal (formalites.entreprises.gouv.fr), carries no state fee, and typically takes around two to three months to complete.

The filing rhythms then diverge: Germany has a monthly (or quarterly) preliminary return plus an annual return, while France has only the monthly CA3. Running both in parallel is where a single provider that handles the two countries on one dashboard saves the most friction, because the deadlines, the returns and the correspondence otherwise pull in different directions every month.

Frequently asked questions

When does a foreign company have to register for VAT in France?

A company established outside France must register for French VAT before it makes its first taxable transaction there. The most common triggers for an online seller are holding or storing stock in France (including goods placed in a French Amazon warehouse under Pan-EU FBA), importing goods into France, and making domestic supplies from French stock. For a non-established company holding French stock there is no registration threshold: the obligation starts with the first item. B2C distance sales into France from another EU country are different and may be covered by the Union OSS scheme instead of a French registration, provided you hold no stock in France.

Does a foreign company need a fiscal representative in France?

It depends on where the company is established. A company established in the EU does not need a fiscal representative and may register directly or appoint an agent (mandataire). A company established outside the EU must check the mutual-assistance list set by the French arrêté of 15 April 2021: businesses from a listed country, which includes the United Kingdom, are exempt and can register without a representative, while businesses from a country not on the list, such as the United States, China, Hong Kong, Switzerland or Israel, must appoint an accredited fiscal representative (représentant fiscal) in France who becomes jointly liable for the VAT. Vaytax registers EU and exempt-list companies but does not act as a fiscal representative.

What is the CA3 return and when is it due?

The CA3 (Formulaire 3310-CA3) is the French VAT return filed under the régime réel normal, which applies to foreign sellers registered in France. It is filed monthly and electronically through the espace professionnel on impots.gouv.fr, and it is due around the 19th of the month following the reporting period, or the 24th in months where you declare import VAT. A nil return is mandatory in a month with no activity. France has no separate annual VAT return: unlike Germany, there is no Jahreserklärung-style year-end filing under the régime réel normal.

How is import VAT handled in France?

Since 1 January 2022 import VAT in France is reverse-charged automatically on the CA3 return rather than paid at the border. If you hold a French VAT number, the import VAT due is pre-filled on your return (available around the 14th of the month) and you declare it and deduct it on the same return, so in the normal case there is no cash outlay for import VAT. This differs from the border-payment model foreign sellers often expect and is a practical cash-flow advantage of a French registration.

Does OSS remove the need to register for VAT in France?

Only for B2C distance sales. The Union One-Stop-Shop lets you report cross-border B2C sales into France from your home EU registration once your EU-wide distance sales cross 10,000 euros, without a French VAT number. But OSS does not cover holding stock in France, importing into France, or domestic supplies made from French stock: those require a local French VAT registration. An Amazon Pan-EU FBA seller whose goods sit in a French warehouse therefore needs a French VAT number even if they also use OSS for other flows.