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.
The VATfaqs digest
Global VAT news, delivered Tuesday and Thursday. Free, curated from 50+ official sources, no spam.
No spam · Unsubscribe any time
Storecove · 2 days ago
France has launched a 2026 e‑invoicing pilot that runs from February to August, allowing businesses to test real invoice exchanges on the French Public Invoicing Portal. The pilot precedes the mandatory e‑invoicing regime that will take effect on 1 September 2026. Storecove will enable clients to join the pilot from mid‑June via its French API and the national Annuaire directory.
VatCalc · 9 days ago
France confirms that its e‑invoicing mandate remains scheduled for 1 September 2026, with no postponement announced. The DGFiP will soften penalty enforcement until at least 1 January 2027 for taxpayers who made best efforts from the start of the first phase, and a contingency deferral to 1 December 2026 is still available. The launch will rely on the Plateforme Agréée network, of which only a fraction are currently active.
e-Invoice.app · 10 days ago
France's e-invoicing reform, effective 1 September 2026, requires all businesses with a French VAT footprint to use approved platforms for issuing and receiving electronic invoices and for transmitting transaction and payment data. The reform mandates structured invoice formats (UBL, CII, Factur-X) following EN 16931 with French extensions and adds four mandatory fields. SMEs and micro-enterprises will join the issuance and reporting obligations on 1 September 2027, while large enterprises must comply from 1 September 2026.
The Invoicing Hub · 29 days ago
France's e-invoicing mandate will enter its first phase on 1 September 2026, requiring large companies to issue and receive electronic invoices and submit e‑reporting to the PPF, while small firms must only receive them. The latest External Specifications v3.2, published 30 April 2026, mandate hourly aggregation of PPF submissions by Accredited Platforms and clarify B2G, G2B, and G2G processing. AFNOR standards are slated for final updates by the end of May 2026 to cover additional use cases such as agriculture and food industry.
Melasoft · about 2 months 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 · 2 months 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.
Put your brand alongside trusted tax-tech intelligence across 150+ countries.
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.
