4 September 2026 • 2 minute read
France delays the entry into force of VAT recodification into the CIBS until 1 January 2027
France has undertaken a major recodification of its VAT legislation, transferring the relevant provisions from the French Tax Code (CGI) to the French Code of Taxes on Goods and Services (CIBS). While intended as a codification without substantive changes, the reform significantly restructures the VAT provisions, incorporates certain concepts derived from CJEU case law and introduces a revised legislative terminology. Originally scheduled to take effect on 1 September 2026, the recodification has been postponed to 1 January 2027. The Government considered that businesses should be granted additional time to familiarise with the new codification, particularly as the reform would otherwise coincide with the rollout of France’s mandatory e-invoicing and e-reporting regime. During a transitional period, references to CGI provisions may therefore continue to appear on invoices until 30 June 2028. The new ordinance also includes a number of technical clarifications and corrections. In particular, it confirms that existing administrative guidance and rulings will remain binding following the transfer of the provisions to the CIBS. It also incorporates VAT measures introduced by the Finance Act for 2026 and consolidates the VAT deduction rules into a dedicated subdivision.
Key takeaway / recommendation
Businesses should use the postponement period to ensure that the CIBS recodification is fully factored into ongoing VAT analyses, audits, transactions and compliance projects. Although intended not to change the substantive law, the new codification may affect the interpretation and organisation of VAT rules. Businesses should therefore reassess existing positions, update internal VAT references and systems, and prepare for the interaction between the CIBS and the forthcoming e-invoicing regime.
