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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Bloomberg Tax · about 15 hours ago
France's Tax Agency updated its administrative doctrine on 8 July 2026, clarifying VAT treatment for goods sales, lease-purchase options and related transactions. The guidance confirms VAT applies to transfers of tangible goods where the purchaser obtains owner-like disposal rights, treats hire-purchase arrangements and retention-of-title sales as supplies of goods, and classifies LPOs for tangible property as taxable services until the purchase option is exercised.
VatIT · 1 day ago
France will require all VAT-taxable businesses to receive electronic invoices from 1 September 2026, with large and mid-sized firms also issuing them. Smaller companies must issue and e-report from 1 September 2027, and all must use a government-approved Plateforme Agréée to comply.
VatCalc · 2 days ago
France confirms its e-invoicing and e-reporting launch remains on 1 September 2026, with a Practical Guide to help businesses transition. The guide outlines six priorities and allows temporary use of paper or PDF invoices during technical difficulties, with penalties softened until January 2027.
SharedServicesLink · 5 days ago
France's B2B e-invoicing mandate will see new technical specifications released by AFNOR, with the first mandatory phase starting 1 September 2026. The documentation expands on business use cases, invoice data flows, third-party relationships, and ecosystem interactions to guide businesses, software vendors and ASPs.
Global VAT Compliance · 5 days ago
France: The Administrative Court of Appeal of Paris has ruled that input VAT cannot be deducted for pre-incorporation acquisitions unless the transaction is clearly linked to the future company. The decision underscores the need for consistent documentation and evidence that the purchase was made on behalf of the company before incorporation.
RTC Suite · 12 days ago
France is implementing a new continuous transaction control (CTC) model that requires all businesses to use registered Plateformes Agréées (PAs) and the Public Billing Portal (PPF) for domestic B2B e‑invoicing, e‑reporting, and payment reporting. The mandatory rollout begins in September 2026 for e‑invoicing and e‑reporting, with payment reporting added in September 2027. ERP systems must be updated to handle new invoice lifecycle statuses (F1, F2/F3, F6, F10) and master‑data requirements before these deadlines.
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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.
