Four VAT reporting changes in France – What’s new and what’s next?

The new French VAT return (CA3- 3310) has been officially released. This incorporates the new 2022 requirements including the import VAT reverse charge. The first return to be submitted using the new form was January 2022 which had to be submitted by February 14.

From January 1, 2022, the declaration and payment of import VAT is made directly in the French VAT return instead of the customs declaration i.e. as a reverse charge self-assessed by the taxpayer. The use of the reverse charge for import VAT will be compulsory for all businesses registered for VAT in France (including non-taxable persons who have an intra-community VAT number) and there will be no prior authorisation to use this postponed import VAT procedure required.

In addition, this year sees France replace its DEB return (“Declaration des Echanges de Biens”) into two new reporting obligations. France has followed the majority of other EU member states by introducing a separate Intrastat declaration (“l’enquête statistique”) and an EC Sales List (“l’état récapitulatif des livraisons de biens intra-UE”). Historically, France had included both requirements within the single DEB return.

France will introduce a mandatory requirement for businesses to issue e-invoices in a phased approach between July 1, 2024 and January 1, 2026. Businesses will have an obligation to send e-invoices with mandatory fields in a predefined structured format to customers and the French Tax Administration. France’s national e-invoicing platform is Chorus Pro with a new public invoicing portal (Portail Public de Facturation) being launched, and the main e-invoicing format and standard is Factur-X. In addition to mandatory e-invoicing between French businesses, there will also be a new digital reporting requirement for B2C transactions and transactions with foreign customers. It is anticipated that the French tax authority will be able to use the data it receives to pre-populate the French VAT returns for taxpayers in the future. The final technical requirements for e-invoicing will be released in Q2/2022.