Import VAT 2026: Note BOD specifies tax representation obligations

On 29 December 2025, the Directorate-General for Customs published Note BOD No. 25000246 (attached) to clarify the rules applicable to the VAT representation of foreign companies importing goods into France. This note, which does not create new rules, aims to consolidate and explain in a practical way the obligations already in force, in order to facilitate their application as soon as possible. 1 January 2026.

Two key schemes for foreign companies:

• The international representative : An intermediary managing VAT-related administrative formalities, without payment liability. Ideal for taxable transactions in France.
• The tax representative : A representative in France, responsible for VAT declarations and payment. Mandatory for non-EU enterprises which have not signed the tax agreement with France (see: Decree of 15 May 2013 establishing the list of signatory countries), with exceptions.

For undertakings established in the EU or in a third country having concluded a tax agreement with France, there is not required to identify in France if they only carry out transactions under the VAT suspension regime (article 277 of the CGI). In other cases, they must identify with VAT in France.

For companies established outside the EU and in a country without tax agreement with France :

• If they realize only exempt transactions (regimes 42 and 63, or exemptions provided for in Article 262 of the CGI) identify with DGFiP. On an exceptional basis, those who have initiated a process of appointing a one-time tax representative before 31 December 2025 may continue to benefit until 31 December 2026. After that date, they must designate a permanent tax representative or international representative.
• If they carry out other types of taxable transactions, they must designate a international representative or permanent tax representative.

To facilitate the application of these rules, the Customs has attached flowchart explanatory diagrams, enabling rapid identification of the steps to be taken. These diagrams are accessible via direct links in our publication.

In practice, this note constitutes the reference administrative doctrine for 2026. The companies concerned are invited to refer to them to secure their import operations ensure compliance with their VAT obligations.

2 flowchart representing EU

1 NO 25000246 of 29 Dec 2025 presentation tax representation VAT

3 flowchart representing tax outside the EU