9 February 2026
Transfer of VAT provisions from the French Tax Code to the Goods and Services Tax Code from 1 September 2026
In practice, the VAT rules will be reorganised under a new architecture and will be fully renumbered, with extensive redrafting intended to improve readability and consistency.
Although described as a simple transfer of the provisions, it is more than a renumbering: it will substantially redraft the provisions, standardise terminology, codify CJEU case law (including the “direct link” test for consideration or the VAT fixed establishment concept), reshape the presentation of exemptions and VAT rates (including an new explicit “zero rate (0%)” concept), reorganise the rules by business sector, consolidate special regimes, move certain procedural and documentary obligations to the regulatory level.
In addition, it will embed EU-mandated technical measures, including key elements linked to the ViDA (VAT in the Digital Age) package, with phased implementation.
This VAT recodification will not alter the separate e-invoicing reform to be rolled out from 1 September 2026 (all French-established businesses must be able to receive e-invoices from that date).
To ease the transition, references to previous VAT provisions in administrative acts, invoices and contracts may be read as references to the corresponding Goods and Services Tax Code provisions, including for documents producing effects up to 31 December 2027.
Key takeaway / recommendation
Practitioners and companies must adapt to the new numbering and refreshed terminology in practice to avoid misinterpretations during audits and disputes.
Update templates, invoice references and legal documentation using concordance tables;
Stay alert, as the ordinance is not yet final and remains subject to parliamentary ratification, and may be supplemented by draft implementing measures released for public consultation.
Reference / Link to document
