French VAT for Amazon FBA Sellers | Complete 2025 Guide

What TVA is and how it works in French e-commerce

In France, VAT is called TVA (Taxe sur la Valeur Ajoutée). It’s the same core mechanism you know from other EU countries, but with local rules, rates, and deadlines. You charge TVA on B2C sales, report monthly or quarterly, and account for both output tax on sales and input tax on business costs—including Amazon fees and logistics services. A key difference in the FBA world is that the place of storage triggers registration and reporting duties. If you use Pan-EU FBA or cross-border distribution, your SKUs may appear in several countries at once—and each has its own TVA rules. Add to that the OSS system for distance sales and adjacent topics like EPR, Intrastat, and upcoming e-invoicing. It sounds like a thicket of regulations, but it’s manageable once you understand the order of operations and the most common pitfalls.

What you’ll find in this step-by-step guide

This guide takes you from the decision to enter the French market all the way to stable, repeatable compliance. First, you’ll learn exactly when you must register for TVA and how to do it without unnecessary downtime. Next, we’ll cover operational obligations: which rates apply to different product categories, how returns and payments work, where most errors occur, and what the penalties are for delays. We’ll show you how to interpret Amazon programmes through a tax lens, how VAT is handled on imports, and what Procedure 42 is. You’ll also get clear explanations of side requirements that often block sales—EPR, statistical reporting, and preparations for e-invoicing. The whole thing is intentionally shaped for a 25–35-year-old entrepreneur: concrete, jargon-light, focused on practice, automation, and risks that truly affect cash flow. By the end, you’ll know what to do today, what to plan for later, and how to structure your processes so the French market sells—and TVA doesn’t eat your time.

When You Must Register for VAT in France

The Basic Rule for Amazon FBA Sellers

If you sell through Amazon FBA, the rule is simple: if your goods are physically stored in a French warehouse, you are required to register for local VAT (TVA).
There are no sales thresholds or exemptions — the obligation arises the moment your product is transferred into a warehouse located in France, even if it hasn’t yet been sold.

This doesn’t mean that such storage automatically creates a fixed establishment. Under VAT law, a “fixed establishment” requires a permanent presence of both human and technical resources capable of carrying out business activities or providing services. Purely storing goods — without staff or infrastructure — doesn’t meet that definition.

Instead, the registration obligation comes from the fact that moving your own goods between EU member states (for example, from Germany to France) is treated as a deemed intra-Community supply (dispatch) in the country of origin, and a deemed intra-Community acquisition in the country of destination.
This transfer of own goods, defined under Article 17 of the EU VAT Directive, is a taxable transaction that requires a French TVA number.

In practice, this means that you must register for VAT before the first shipment of goods is sent to a French Amazon warehouse.
It’s this mechanism — not the sale itself — that triggers local tax obligations. Failure to register, even if your inventory is already stored in France, is one of the most common issues found during audits. Amazon may also flag it internally, as the platform performs VAT compliance checks under its FBA and Pan-EU programmes.

Non-EU Sellers

For businesses established outside the European Union, the rules are stricter but clear.
If your company is based in a third country — such as the United States, Canada, Switzerland, or Hong Kong — and your goods are stored in France, you must register for VAT from the very first transaction, with no threshold.

Under French tax law (Article 289 A of the Code Général des Impôts), non-EU businesses are generally required to appoint a fiscal representative.
This representative must be based in France, approved by the French tax authorities, and is jointly liable for your VAT obligations. They act on your behalf — filing returns, communicating with the tax office, and handling compliance.

However, not all non-EU countries are subject to this requirement.
France has signed mutual administrative assistance agreements with several countries, exempting their businesses from appointing a fiscal representative. These include the United Kingdom, Norway, Turkey, Iceland, and Japan.
Companies from these countries may choose to appoint a representative but are not required to do so. Nevertheless, they must still register for French TVA if their goods are stored in Amazon’s French warehouses or sold to French customers.

EU-Based Sellers

For businesses established in another EU member state, the principle is the same: storing goods in France automatically creates a TVA registration obligation, regardless of turnover.

If, however, you do not store stock in France but ship products to French consumers from another EU country (for example, from Poland or Germany), the EU-wide distance selling threshold of €10,000 per year applies.
Once this threshold is exceeded, you must charge the VAT rate of the customer’s country — in this case, French VAT for sales to France.
You can handle this either by registering for French TVA directly or through the OSS (One Stop Shop) scheme, which allows you to report and pay VAT on cross-border B2C sales from a single EU country.

Keep in mind that OSS does not apply when goods are stored in France.
If your stock physically sits in a French warehouse, local registration is always required. The OSS system covers only shipments made between EU countries where the seller does not hold inventory in the destination country.

The Pan-European FBA Programme

The Pan-European FBA (Pan-EU) programme allows Amazon to store your products in multiple EU countries simultaneously, improving delivery times and product availability.
Under Pan-EU, Amazon decides where to place your inventory — it may move your products to warehouses in Germany, France, Spain, Italy, Poland, or the Czech Republic, even if you didn’t send them there yourself.

From a tax perspective, this means you must hold valid VAT numbers in every country where Amazon physically stores your goods.
Transfers between Amazon’s warehouses are treated as intra-Community movements of own goods, which — under EU law — are deemed supplies and acquisitions that trigger VAT registration and reporting obligations in each relevant country.

Amazon clearly states in Seller Central documentation that Pan-EU sellers must have active VAT registrations in all participating countries. Otherwise, Amazon may restrict or suspend selling privileges for that market until a valid VAT number is provided or proof of registration in progress is submitted.

For sellers, this means planning ahead: before activating Pan-EU, identify all potential storage countries and prepare VAT registration in each one.
A well-organised system of declarations and reports allows your business to run smoothly — without sudden account freezes or surprise letters from the French tax authorities.

The Fiscal Representative in France

Who Needs One

In France, any business established outside the European Union that carries out taxable activities subject to French VAT (TVA) must appoint a fiscal representative (représentant fiscal).
This requirement is set out in Article 289 A of the French Tax Code (Code Général des Impôts) and detailed in the official guidelines published in BOFiP (Bulletin Officiel des Finances Publiques).

The fiscal representative acts on behalf of the foreign taxpayer and handles all formalities related to French VAT compliance. They file TVA returns (such as Form CA3), communicate with the French tax office, and ensure that all filings and payments are correctly processed via impots.gouv.fr.
In practice, this representative serves as the main point of contact between your company and the French tax authorities — especially if you have no local office or staff in France.

For non-EU Amazon FBA sellers, having a fiscal representative is an essential part of operating legally in the French market.
Your representative not only registers your business for TVA but also manages your ongoing obligations — submitting returns, monitoring payments, verifying data accuracy, and assisting with VAT refund claims (refund TVA).

The Role and Liability of a Fiscal Representative

A French fiscal representative has a special legal status: they are not simply a consultant but a jointly liable entity for their client’s VAT obligations.
This means that if a declaration is incorrect or VAT is left unpaid, the French tax authorities (Direction Générale des Finances Publiques) can demand payment directly from the representative.

Because of this shared liability, the BOFiP rules impose strict eligibility requirements on fiscal representatives. They must be accredited, demonstrate financial reliability, and often provide a financial guarantee or security — typically set at €10,000 if the level of risk cannot be otherwise assessed (as per the decree of 20 April 2022).
As a result, fiscal representatives carefully vet their clients before accepting an engagement.

In practice, a fiscal representative typically:

Submits VAT (TVA) declarations (CA3) and periodic reports on behalf of the client,
Registers the company for TVA and obtains a VAT number in the format FR + key + SIREN,
Manages all communication with the tax authorities via impots.gouv.fr,
Maintains VAT records and supervises payment processes,
Handles refund claims for foreign businesses under the 13th EU VAT Directive (refund TVA).

It’s important to note that the SIREN (a 9-digit business identifier) forms part of the French VAT number and identifies the company in official registers.
The SIRET, which adds five additional digits referencing a specific establishment, applies only to businesses with a physical branch or fixed establishment in France.
Foreign companies without a French office typically receive only a FR VAT number based on their SIREN, not a SIRET.

Countries Exempt from the Requirement

Not all non-EU businesses are required to appoint a fiscal representative.
The exemption applies to residents of countries that have signed mutual administrative assistance agreements with France for the enforcement of tax claims and exchange of VAT-related information.
These agreements operate similarly to the EU’s Directive 2010/24/EU and Regulation 904/2010.

If your country is on this list, you may register directly for TVA without appointing a representative.

Examples of countries benefiting from this exemption include the United Kingdom, Norway, Iceland, Japan, Australia, New Zealand, South Korea, India, Mexico, South Africa, and Turkey.
The full and up-to-date list is published by the French Ministry of Finance in an arrêté ministériel and in the BOFiP section dedicated to Article 289 A CGI.
Since the list may be updated periodically, it’s important to check the latest version before starting the registration process.

For companies from these countries, a fiscal representative is not legally required — but can still be highly practical.
The French tax system is complex, and communicating with authorities effectively requires knowledge of local procedures, terminology, and deadlines.

Electronic Procedures and Payments

All interactions with the French tax administration are handled electronically.
Registration, VAT returns, corrections, and refund applications are all submitted via the impots.gouv.fr platform.
Through this same portal, the fiscal representative — or the taxpayer directly (if exempt from representation) — can correspond with the tax authorities and upload required documents.

Since 1 July 2021, VAT refund requests for non-EU businesses (so-called refund TVA under the 13th Directive) must be submitted exclusively online, typically by the fiscal representative, using a secure mailbox on impots.gouv.fr.

VAT payments can be made via télérèglement (a SEPA direct debit) or, in some cases, via bank transfer (virement) to the account specified by the French tax office (SIEE).
Payment instructions and account details are provided individually by the SIEE once registration is complete.

Thanks to these digital procedures, all VAT obligations — from registration to payment — can be handled remotely, without any physical presence in France, as long as you have an active FR VAT number and, where required, a properly appointed fiscal representative.

VAT Registration Process in France

Where and How Registration Takes Place

Registering for French VAT, known as TVA (Taxe sur la Valeur Ajoutée), is handled by the Service des Impôts des Entreprises Étrangères (SIEE), a specialised branch of the French tax administration based in Noisy-le-Grand, just outside Paris. This is the central authority responsible for processing VAT registrations for all foreign entities that have no fixed establishment or registered office in France.

Both EU and non-EU businesses register using the same form, called IMP (Déclaration d’identification à la TVA). It is a standard application containing key company details, a description of business activities, and, where relevant, information about the appointed fiscal representative. Non-EU applicants are required to complete additional sections related to their authorised representative and company ownership structure.

Alongside the form, SIEE expects a set of supporting documents proving the company’s legal existence, activity, and tax status. For EU companies, this typically includes a recent extract from the national company register, confirmation of an active EU VAT number, articles of association or founding documents, identification of the legal representative, and proof of the registered address. Non-EU applicants must provide a broader set — such as a certificate of incorporation, articles of association, passports of directors, a tax residency certificate, and an original, signed power of attorney for the fiscal representative, often with an apostille. A proof of a French correspondence address, usually the representative’s, is also required.

The French authorities are particular about document authenticity. Signatures must be original, and documents may need to be notarised or officially certified. Anything not written in French must be translated by a sworn translator (traducteur assermenté).

What to Expect During Registration

During the registration process, SIEE may request extra information to clarify the nature of the business. Sellers using Amazon FBA are frequently asked to explain the types of goods they sell, how their logistics are structured, and where their inventory is stored. The authorities may also request an EORI number for companies that move goods between countries or import them from outside the EU. Any EORI issued by an EU member state — such as a Polish or German EORI — is fully recognised in France.

The registration process typically takes between four and eight weeks, though it can extend to twelve during peak periods such as late in the year. SIEE begins reviewing the application only once it has received the complete documentation, either in original form or as certified copies. Delays are common if information is missing, so attention to detail is crucial.

A short written summary of the business model — a note explicative — can help speed up the process. This brief explanation should outline what the company does, how sales are made (for instance, through Amazon FBA), where goods are stored, and how they move across borders. Such context helps officials categorise the business correctly for tax purposes.

Occasionally, the authorities request evidence of trading activity. Examples include copies of invoices, order confirmations, or screenshots from Amazon Seller Central to prove that actual sales are taking place. This step, increasingly standard in the e-commerce sector, helps the French administration prevent fraudulent or inactive registrations.

Once registration is approved, SIEE issues a formal notification containing the newly assigned French TVA number and instructions on how to activate your account on the impots.gouv.fr online portal. It’s worth noting that the taxpayer account is not created automatically — the tax office provides an identifiant fiscal and temporary login details, which you use to activate your profile under the “Professionnels” section. From that moment, you can submit TVA returns (CA3), statistical reports (DES/EMEBI), and pay taxes electronically via télérèglement.

Understanding VAT Identification Numbers

Every business registered for French VAT receives a number in the format FR + two-digit key + nine-digit SIREN. The two-digit key is an algorithmic control code assigned by the administration to ensure numerical accuracy, while the nine-digit SIREN serves as the main business identifier in France’s INSEE registry. All entities registered for TVA — including foreign companies without a French office — are given a SIREN.

In contrast, the SIRET number adds five additional digits to identify a specific establishment within France. It is only assigned to companies that have a fixed establishment in the country, such as their own warehouse, office, or employees. Amazon FBA sellers, whose stock is stored in Amazon’s facilities rather than their own, do not receive a SIRET, only a SIREN-based FR VAT number.

This VAT number is vital for day-to-day operations. Amazon requires sellers to enter it in the Tax Information section of Seller Central and automatically verifies its validity through the VIES (VAT Information Exchange System). If the number appears inactive or unconfirmed, Amazon may temporarily restrict sales to French customers or apply the so-called “deemed supplier” model, under which Amazon itself accounts for VAT on your behalf.

Once the number is active, you can legally sell to French consumers, issue invoices with French VAT, file periodic CA3 declarations, and meet related compliance duties such as EPR and Intrastat reporting. It also opens the door to reclaiming input VAT on French business expenses — for instance, Amazon service fees or domestic transport costs — ensuring that your operations remain fully compliant and financially efficient.

VAT (TVA) Rates in France

The Current Rate Structure

The French VAT system — locally known as TVA (Taxe sur la Valeur Ajoutée) — is among the most detailed in Europe. It features four principal tax rates, each applied according to the type of goods or services sold. The legal framework is set out in Articles 278 and following of the Code Général des Impôts, with practical guidance published in the BOFiP (BOI-TVA-LIQ-30).

The standard rate, currently 20%, applies to the vast majority of goods and services. It covers items such as electronics, clothing, cosmetics, homeware, sporting goods, toys, and computer equipment. For most online sellers — especially those operating through Amazon FBA — this is the rate used in nearly all cases.

A reduced intermediate rate of 10% applies to specific sectors, including catering (such as takeaway meals), hotel accommodation, passenger transport, residential building renovation, and certain processed food products. It is less common in e-commerce but may be relevant for hybrid product categories, for instance, curated food boxes or gift bundles combining several types of goods.

The lower rate of 5.5% applies to items considered of essential social importance: basic unprocessed foodstuffs, printed books and e-books, newspapers of a general or informational nature, museum admissions, cultural events, household energy supplies, and certain housing-related services. France was one of the first EU countries to equalise VAT rates for printed and digital books after the implementation of Directive 2018/1713, which amended the original VAT Directive 2006/112/EC.

Finally, a super-reduced rate of 2.1% applies to a very narrow group of products — mainly reimbursed medicines, certain pharmaceutical items, daily newspapers, some cultural publications, and specific artistic services. In the context of online sales, it plays a marginal role but still appears in Amazon’s product tax database, particularly for digital press and informational content.

It is worth noting that France’s overseas territories — including Guadeloupe, Martinique, Réunion, French Guiana, and Mayotte — operate under separate local VAT regimes, with rates such as 8.5%, 2.1%, or 1.75%. This guide focuses solely on the metropolitan rates applicable in mainland France.

There is no separate “eco rate” in France. Certain energy-efficiency products — such as thermal insulation or solar installations — may benefit from a temporary reduced rate of 5.5%, but only as part of specific environmental policy programmes approved by the French government.

Choosing the Correct Rate on Amazon

For Amazon FBA sellers, the 20% standard rate is the default and safest choice. Amazon automatically assigns it to most product categories, and unless a product clearly qualifies for a reduced rate, sellers should apply 20% to ensure compliance.

The platform uses a system of Product Tax Codes (PTC), where each code corresponds to a specific TVA rate defined by the Direction Générale des Finances Publiques (DGFiP). These codes determine the rate applied to each transaction. Sellers should review their product tax codes regularly in the VAT Calculation Service section of Seller Central, as Amazon periodically updates them in response to legal changes.

For example, electronics, household appliances, cosmetics, clothing, and sports accessories are taxed at 20%; printed books and e-books at 5.5%; unprocessed food at 5.5%; catering and takeaway services at 10%; and pharmaceuticals or informational press content at 2.1%.

Amazon operates under the “marketplace deemed supplier” model, meaning that in certain scenarios — primarily B2C sales made by non-EU sellers — Amazon itself is responsible for charging and remitting VAT on behalf of the seller. When this applies, Amazon may automatically adjust the VAT rate linked to a product if it detects an inconsistency or a mismatch between the product category and the assigned tax code.

When selling from within France, the VAT liability arises either at the moment of delivery or payment, whichever occurs first, as defined in Article 269 of the Code Général des Impôts. In the FBA model, where Amazon acts as a logistics operator and records the transaction at the time of shipment, the VAT is due once the platform confirms the sale.

Under Article L112-1 of the French Consumer Code (Code de la Consommation), all prices displayed to consumers must include VAT — referred to as TTC (toutes taxes comprises). In practice, this means that if you change the applicable tax rate but keep your listed price unchanged, the difference directly reduces your profit margin. For multi-country FBA sellers, this is particularly important: even a minor change in the TVA rate in one market can alter profitability across the entire Pan-EU network.

In summary, use 20% as your default rate unless your products clearly qualify for a reduced category, such as books, food, or media. Always confirm the correct rate through the official BOFiP database or a qualified VAT advisor. Within Amazon’s system, ensure that each listing has the appropriate Product Tax Code and verify it periodically in the VAT Calculation Service. Doing so keeps your compliance watertight — and ensures Amazon won’t suspend your offers or hold your funds due to incorrect tax data.

Filing and Paying VAT in France

Filing Frequency and CA3 Returns

In France, VAT is reported using the CA3 form, the central reporting tool in the TVA system. This form consolidates both output VAT (tax on sales) and input VAT (tax on business expenses). Based on this balance, the tax authority determines whether additional tax is due or whether the business is entitled to a refund.

There are two main VAT accounting regimes in France: the régime réel normal, which involves monthly filing, and the régime réel simplifié, which provides for quarterly filing with advance payments and an annual summary return (CA12).

Under the régime réel normal, monthly returns are required when annual VAT liability exceeds €4,000. The régime réel simplifié applies when the VAT liability stays below that threshold and annual turnover does not exceed €818,000 for goods or €247,000 for services.

However, in practice, foreign businesses — including Amazon FBA sellers without a French establishment — are always placed under the monthly régime réel normal. The SIEE (Service des Impôts des Entreprises Étrangères) does not apply the simplified quarterly regime to non-resident entities, even if their turnover is low. For foreign sellers, monthly VAT filing is the mandatory standard.

The CA3 form is available exclusively online via the impots.gouv.fr portal under the Professionnels section. The digital version is integrated with the EDI (Échange de Données Informatisé) system, which automatically transmits data between the taxpayer and the French administration. Once completed, the form automatically calculates the payable or refundable amount and generates a unique VAT payment reference number (référence de paiement TVA).

Each CA3 return includes domestic sales, intra-Community acquisitions and supplies, imports, exports, deductible VAT, and any corrections from previous months.

Submission Deadlines

VAT returns must be submitted each month between the 15th and the 24th of the month following the reporting period. The exact deadline depends on the company’s status and the relevant tax office.

For foreign businesses managed by SIEE, the filing deadline is typically the 19th of the following month — meaning that, for example, the return for September must be submitted by 19 October.
For French-resident companies (with a SIRET or local establishment), deadlines may vary depending on the region and the initial letter of the company name, usually falling around the 24th.

If the 19th falls on a weekend or public holiday, the deadline automatically moves to the next working day.

All VAT returns must be filed electronically; paper forms are no longer accepted. Once submitted, the portal generates an accusé de réception — an official acknowledgment of receipt — which must be kept on record. In the event of a tax audit, the administration may request this confirmation as proof of timely submission.

Paying VAT in France

VAT payments in France are made entirely electronically. The payment step is integrated into the CA3 filing process, so once the declaration is submitted, the taxpayer is guided directly to the payment section.

The most common method is télérèglement, an authorised SEPA Direct Debit. When submitting the return, the taxpayer selects paiement par télérèglement and authorises their bank account to be debited. The French tax administration automatically collects the payment on the specified date, eliminating the need for manual transfers.

The administration accepts SEPA bank accounts from any EU or EEA country, including Poland, Germany, the Netherlands, or Spain — as long as the IBAN begins with a SEPA country code.

If the account is located outside the SEPA zone, payment can be made via bank transfer (virement bancaire). In such cases, the tax office provides the bank details and a unique reference number that must be included in the payment reference field.

Once payment is processed, the system issues an avis de paiement TVA, or payment confirmation. Together with the accusé de réception, it forms the complete proof of compliance, which should be retained for audit purposes.

Penalties and Late Payment Interest

France enforces strict penalties for late VAT filings or payments. According to Article 1727 of the French Tax Code (CGI), late payment interest accrues at 0.20% per month, equivalent to 2.4% per year.

Under Article 1731 CGI, a 5% surcharge applies to VAT paid after the deadline.
If the declaration is not filed at all — or is submitted only after repeated reminders — an additional penalty of 10% may be imposed, as stated in Article 1731 bis CGI.

Timely filing and payment are therefore essential to maintain compliance and avoid administrative sanctions or cash flow disruptions.

VAT Refunds

When the input VAT on purchases exceeds the output VAT on sales, the resulting balance creates a VAT credit (crédit de TVA), which can be reclaimed.
To request a refund, businesses submit an electronic application called demande de remboursement de crédit de TVA via impots.gouv.fr, typically alongside the CA3 return. The request is processed directly by SIEE, which may ask for supporting invoices to verify the deduction claims.

Refunds generally take between four and eight weeks, depending on case complexity and processing volumes. For Amazon FBA sellers, this mechanism is particularly important, as it allows recovery of VAT paid on Amazon fees, transport costs, logistics services, and other local business expenses — ensuring that French VAT remains a neutral, recoverable cost rather than a permanent burden.

Penalties and Sanctions

Late VAT Filings

The French tax administration treats delays in filing VAT returns with utmost seriousness. Every missed deadline is automatically recorded in the system, and penalties are imposed under clearly defined thresholds set out in the Code Général des Impôts (CGI).

If a business fails to submit a VAT return on time but files it within 30 days of receiving a formal notice (mise en demeure), the penalty amounts to 10% of the VAT due, according to Article 1731(1) CGI. If the declaration is still not submitted within 30 days after the notice, the tax office increases the penalty to 40%, as per Article 1731(2) CGI. When the administration itself detects the omission — for example, during an audit or based on data from Amazon — and determines that the activity was intentionally concealed, the maximum penalty of 80% of the VAT due applies (Article 1732 CGI).

However, the French system allows for a partial reprieve under the principle of régularisation spontanée — voluntary correction. If a taxpayer submits a missing declaration and pays the outstanding VAT before any formal audit or enforcement begins, the administration may reduce the penalty back to 10%. This is a common practice among businesses seeking to regularise their position without triggering full enforcement procedures.

Penalties also apply to incomplete or incorrect declarations. If the tax office identifies errors, it may issue a correction request and a second mise en demeure. Failure to respond within the given timeframe leads to further penalties being applied.

All penalties and interest charges are displayed in the taxpayer’s online account under the “Pénalités et intérêts de retard” section on impots.gouv.fr. If outstanding declarations or payments remain unresolved, the tax office may also withhold any VAT refunds (crédit de TVA) until full compliance is restored.

Late VAT Payments

When a VAT return is filed on time but the payment is not made by the due date, the French tax administration imposes a separate financial penalty. The standard surcharge is 5% of the unpaid VAT, according to Article 1731 CGI, and it applies regardless of the length of the delay.

In addition, Article 1727 CGI stipulates late payment interest at 0.20% per month — equivalent to 2.4% annually. Importantly, interest is charged for every month started, even if the delay lasts only a few days.

If payment is still not made after a reminder, the tax authorities issue an “avis de mise en recouvrement” (AMR) — a formal enforcement notice that serves as an executive order, authorising compulsory recovery of the debt. This document has the same legal force as a court-issued payment order and allows the French administration to collect the funds directly from a bank account if the business holds assets in France.

For non-resident entities, the AMR may be sent to the fiscal representative, who is jointly liable under French law for the client’s VAT obligations.

In exceptional cases, taxpayers may request a remise gracieuse — a discretionary waiver of penalties or interest. Such requests must be made in writing (lettre de demande de remise gracieuse), supported by full justification and documentation — for example, screenshots showing technical issues within the impots.gouv.fr system. These requests are reviewed on a case-by-case basis by the DGFiP (Direction Générale des Finances Publiques), and the decision is final, with no right of administrative appeal.

Consequences for Amazon Sellers

For Amazon FBA sellers, VAT non-compliance carries a double risk — fiscal and operational. Since 2021, under Article 283 bis CGI and the EU DAC7 directive, online platforms are legally required to monitor their users’ tax compliance and cooperate with tax authorities. Amazon, therefore, must act if French tax authorities report that a seller’s VAT status is inactive or non-compliant.

In practice, when the DGFiP identifies a missing VAT declaration or an invalid VAT number, it can issue a VAT non-compliance notice to Amazon. Upon receiving such notice, Amazon is legally obliged to restrict or suspend the seller’s activity until the issue is resolved. Typically, this happens within 30 to 60 days of the non-compliance being detected.

The process usually starts with a suspension of offers on amazon.fr. If the seller fails to regularise their VAT situation, Amazon may extend the suspension to the entire account. For those enrolled in the Pan-European FBA programme, losing VAT registration in France automatically breaches the Pan-EU framework, since goods stored in one member state cannot be lawfully distributed across others without an active VAT number.

This leads to broader consequences: sellers may lose access to multiple EU marketplaces, and funds in Seller Central can be frozen. Amazon acts as a “deemed supplier” under Article 14a of Directive 2006/112/EC, meaning it can be held liable for incorrect VAT handling by its users — which is why the platform reacts swiftly and without prior warnings.

To lift such restrictions, sellers must submit the missing declarations, settle outstanding VAT, and obtain confirmation from impots.gouv.fr that their VAT number has been reactivated. Only after the number is revalidated does Amazon restore selling privileges.

In short, the French VAT system leaves little room for improvisation. Punctuality is as important as accuracy. Even minor delays can trigger a mise en demeure, followed by an avis de mise en recouvrement. For Amazon sellers, this means that administrative oversights can directly jeopardise business continuity.

Working with a fiscal representative or professional tax advisor is therefore not optional but essential. A representative can communicate with the authorities securely via the messagerie sécurisée professionnelle, respond to notices, and even apply for penalty relief on your behalf.

In the world of Amazon FBA in France, punctual VAT compliance isn’t merely good practice — it’s a survival strategy.

VAT on Amazon Fees

VAT on FBA Fees, Subscriptions, and Commissions

Since August 2024, Amazon EU S.à r.l., the Luxembourg-based entity responsible for providing services to sellers across the EU, has implemented a unified invoicing model for all Amazon-related fees within the European Union. This means that all charges — from Professional account subscriptions to FBA logistics — are invoiced centrally, but with the correct VAT applied according to the place-of-supply rules.

French VAT (TVA 20%) is applied only when the place of effective use of the service is in France, or when the seller has a registered business or fixed establishment there. In all other cases — for example, when the seller is VAT-registered in another EU member state and operates from Poland, Germany, or Spain — Amazon issues invoices without VAT, marked with the annotation “autoliquidation – article 283-2 du CGI”. This indicates the use of the reverse charge mechanism, under which the buyer, not the seller, accounts for the tax.

If the seller is established outside the European Union and does not have a fiscal representative in France, the place of taxation for Amazon’s services is Luxembourg, where Amazon EU S.à r.l. is based. In that case, VAT is applied under Luxembourg’s tax rules, not France’s.

It’s also important to note that different types of Amazon fees follow different place-of-supply principles. Under Article 259 A, section 4° of the CGI, FBA (Fulfilment) logistics services are taxed in the country where the warehouse is physically located. In practical terms, if your goods are stored and shipped from Amazon’s warehouses in France, your invoice will include 20% French VAT. If your inventory is handled in Germany, Italy, or Spain, Amazon will apply the respective local VAT rate for those countries.

All invoices — for subscriptions, referral fees, storage, packaging, shipping, and returns — are issued by Amazon EU S.à r.l. and automatically generated in PDF format, available in the Tax Document Library section of your Seller Central account.

Recovering VAT as Input Tax

For sellers registered for VAT in France, Amazon fees qualify as deductible business expenses, meaning the VAT shown on those invoices can be recovered in full.
Under Article 271 CGI, input VAT is deductible if the expenses are directly linked to taxable commercial activity and the invoices meet the required formal standards.

Amazon’s invoices comply fully with Article 289 CGI, as they contain all mandatory elements: VAT registration number, tax amount, supplier and customer details, description of the service, invoice number, and issue date. Documents downloaded from the Tax Document Library are digitally signed and have full evidential value under French tax law.

For invoices marked as reverse charge, VAT is not shown on the document, but the responsibility to report it lies with the service recipient. In such cases, the seller must declare the transaction in both sections of the CA3 VAT return — once as output VAT (autoliquidation) and again as input VAT (TVA déductible sur autres biens et services). The transaction is thus tax-neutral, but it maintains the correct reporting continuity.

VAT charged on Amazon invoices can be deducted in the same CA3 declaration that includes your monthly sales. If the VAT on costs exceeds the VAT on sales in a given period, the resulting credit (crédit de TVA) can either be carried forward to the next period or refunded upon request.

Refunds for foreign businesses are handled by the Service des Impôts des Entreprises Étrangères (SIEE) in Noisy-le-Grand.
Under Article 242-0A CGI, the formal processing period for a refund request is three months, but in practice, reimbursements are typically completed within six to eight weeks.

A Practical Example

Let’s assume that, in a given month, Amazon issued the following invoices to your company:
a €39 monthly Professional subscription, including €7.80 of French VAT;
€800 in sales commissions, including €160 of VAT; and
€600 in FBA logistics fees for storage and shipping from France, including €120 of VAT.

The total gross amount comes to €1,726.80, of which €287.80 represents French VAT.
If, during the same period, your French sales generated €500 of output VAT, you may deduct the full €287.80 of input VAT from the Amazon invoices in your CA3 declaration.

As a result, your net VAT payable would be €212.20 (€500 – €287.80).
If, on the other hand, your costs exceeded your taxable sales in that month, you would generate a VAT credit, which could either be carried forward or refunded.

This mechanism plays a crucial role in maintaining healthy cash flow — especially in the early stages of business, when Amazon service fees and advertising costs are high, and sales are still ramping up. Effective VAT management can significantly reduce the tax burden during these growth periods and improve financial stability over time.

Import VAT and Customs Procedure 42

Reverse Charge on Import VAT (ATVAI)

Since 1 January 2022, France has implemented a mandatory import VAT reverse charge mechanism, officially known as autoliquidation de la TVA à l’importation (ATVAI). This system replaced the old regime that required prior authorisation to use the reverse charge. Now, any business holding an active French VAT number (FR TVA) automatically benefits from this treatment.

In practice, this means that when you import goods from outside the European Union, you no longer pay VAT at the moment of customs clearance. Instead, you declare the import VAT directly on your monthly VAT return (form CA3) under the field TVA à l’importation à autoliquider. At the same time, you can report the same amount as deductible input VAT, provided the goods are used for taxable business activities. The result is financial neutrality — the import VAT is accounted for on paper, not actually paid.

Thanks to the integration between the French Customs Authority (DGDDI) and the Tax Authority (DGFiP), import data flows automatically from the customs systems (Delta G / Delta X) into the taxpayer’s account on impots.gouv.fr. In your online account, under the section “TVA à l’importation à autoliquider”, you can view a monthly summary of all imports that must be declared.

For Amazon FBA sellers, this mechanism is a major advantage. Goods imported from China, the UK, or the US into Amazon’s French warehouses — such as Brétigny-sur-Orge or Chalon-sur-Saône — can enter the EU market without pre-financing VAT. All that’s required is that the goods be cleared under your company’s French EORI number and that your French VAT number is indicated in the customs declaration.

It’s important to note, however, that the ATVAI mechanism is available only to businesses registered for VAT in France. Non-EU companies without a French VAT number must act through a fiscal representative or licensed customs broker with French accreditation. That intermediary is responsible for entering the correct VAT details into the customs system and transmitting them to the DGFiP.

This system completely replaces the old import reverse charge authorisation process — no separate applications or permits are now required. The only prerequisites are an active FR VAT number and a correctly completed customs declaration.

Customs Procedure 42 — Importing Without Paying VAT

Procedure 42, known in French as Régime 42, allows businesses to import goods from outside the EU into France without paying VAT at the border, provided that the goods are immediately transported to another EU member state. The legal basis for this regime is Article 291 II 2° of the Code Général des Impôts and Article 143 of the EU VAT Directive 2006/112/EC.

In practical terms, the goods arrive at a French port or customs office, are released into free circulation (imported), but are then shipped directly onward — for example, to an Amazon warehouse in Germany or a logistics hub in Poland. In this case, no VAT is due in France because the movement of the goods is treated as an intra-Community supply (IC-supply), taxed in the country of destination.

To use Procedure 42, several conditions must be met:

the importer must hold a valid VAT number in the destination country (e.g. DE, PL, ES),
the customs declaration must specify procedure code 42 and the recipient’s VAT number,
the goods must physically leave France and be delivered to another EU country, and
transport documents such as the CMR, invoice, and delivery confirmation must prove the actual movement of the goods.

When these conditions are met, the importer avoids paying VAT at the border, and the obligation to account for it shifts to the country where the goods arrive.

Until now, France allowed non-EU companies to use a simplified arrangement known as représentation fiscale ponctuelle — a one-time fiscal representation for participation in Procedure 42. Under this system, a foreign company didn’t need to register for French VAT; it could appoint a local fiscal agent solely for that specific import operation.

However, this simplification is being phased out. Starting 1 January 2026, France will abolish the one-time fiscal representation option as part of the “Plan TVA 2026” reform. It will be replaced by a new intermediary role: the Import Agent (mandataire d’importation), established under Article 289 A bis CGI.

The Import Agent will act as a technical intermediary between the importer, customs authorities, and tax offices. Their role will be limited to ensuring the formal accuracy of customs declarations and verifying key data such as the EORI number and destination country. Unlike a fiscal representative (représentant fiscal), the Import Agent will not be jointly liable for the importer’s VAT debts — their responsibility will be purely documentary.

From 2026 onward, non-EU companies wishing to use Procedure 42 will need to:

hold a valid EORI number and VAT registration in the destination country,
appoint a registered Import Agent in France, or
register directly for French VAT if they plan to conduct ongoing imports through France.

Implications for Amazon Sellers

These upcoming changes are particularly relevant for Amazon FBA sellers, as Amazon increasingly uses its French distribution centres as entry points for goods imported into the EU from third countries. The combination of ATVAI and Procedure 42 currently allows businesses to move products efficiently between customs and warehouses without double-financing VAT at import and during intra-EU transfers.

However, from 2026 onward, non-EU sellers will need to formalise their import procedures to avoid customs delays or blocked shipments. Any business planning to import goods into Amazon’s French fulfilment centres should start preparing now — by consulting a tax advisor or customs agency — to ensure compliance with the upcoming mandataire d’importation requirements and maintain smooth logistics once the new rules take effect.

In short, while ATVAI and Procedure 42 offer powerful tools for managing VAT flows efficiently, they also demand administrative precision. Understanding these mechanisms — and anticipating the 2026 reforms — is essential for keeping your cross-border supply chain compliant and uninterrupted.

Summary and Expert Recommendations

Key Risks and Best Practices

Selling through Amazon FBA in France offers vast potential — but it also means operating under one of the strictest tax administrations in Europe. The French tax authority (DGFiP) is known for its precision and low tolerance for procedural errors. Mistakes in VAT registration, reporting, or invoicing can quickly lead to account suspension, blocked refunds, or deactivation of the French VAT number.

The biggest compliance risk for FBA sellers remains failure to register for VAT after goods are first stored in France. Many businesses underestimate that simply moving inventory under Amazon’s Pan-European FBA programme automatically triggers VAT registration obligations in every country where Amazon holds stock. Missing a French VAT number (FR TVA) can result in tax arrears, penalties (10%, 40%, or even 80% of the VAT due), and formal notification to Amazon under Article 283 bis CGI — often followed by immediate sales suspension on the French marketplace.

A second major risk lies in improper handling of import VAT. Non-EU sellers often assume that clearing goods through Germany or the Netherlands covers all EU operations. In reality, if the goods enter via France, the importer must comply with French VAT rules — including the use of autoliquidation de la TVA à l’importation (ATVAI) or Procedure 42. Incorrect customs coding can lead to shipment holds or demands for immediate VAT payment at import.

The third area of exposure concerns fiscal representation and EPR (Extended Producer Responsibility). For non-EU companies, appointing a fiscal representative (représentant fiscal) is typically mandatory. Without one, VAT refunds and filings may be impossible to complete. In addition, France’s EPR legislation requires a UIN (Unique Identification Number) for packaging, electronics, batteries, or textiles. Amazon automatically blocks listings lacking valid EPR numbers, and non-compliance can result in penalties of up to €100,000 from French authorities.

To manage these challenges effectively, sellers should adopt a few key best practices:

Maintain a centralised register of all VAT numbers in countries where Amazon stores your inventory.
Download and archive monthly VAT transaction reports and invoices from Amazon EU S.à r.l. in the Tax Document Library.
Apply ATVAI for all imports via France and monitor your import data monthly on impots.gouv.fr.
File CA3 VAT returns on time each month and verify payment status through your avis de paiement TVA.
Stay in regular contact with your fiscal representative or a specialised VAT compliance agency.

For French authorities, two things build trust: accuracy and punctuality. Businesses that maintain both typically face fewer audits and enjoy smoother refund processing.

When to Work with a VAT Advisor

While VAT registration and filing can theoretically be done independently, in cross-border e-commerce, professional support saves weeks of effort and prevents costly mistakes. You should strongly consider working with a VAT specialist in the following cases:

When selling from outside the EU.
France requires non-EU sellers to appoint a fiscal representative, who not only handles all formalities but also shares liability for correct reporting.
When using Pan-European FBA.
Since Amazon redistributes inventory across multiple EU countries, coordinated VAT registration is essential. France’s SIEE office often requests original documents and certified translations, which a tax advisor can streamline and manage across jurisdictions.
When importing through France.
From 2026 onwards, non-EU importers will need an Import Agent (mandataire d’importation) to use customs Procedure 42. Partnering with a customs or VAT advisory firm ensures that clearance proceeds smoothly and that your data aligns correctly across DGDDI and DGFiP systems.
When applying for a VAT refund.
France’s VAT credit (crédit de TVA) process is digital and bureaucratic. A professional intermediary can file refund requests, monitor DGFiP communication, and often shorten the processing time from the statutory three months to about six weeks.
When unsure about VAT rates.
France applies four VAT rates — 20%, 10%, 5.5%, and 2.1% — each with numerous exceptions (food, e-books, household goods, eco-products). Expert advice can prevent underpayments, overcharges, or retroactive corrections.

Professional VAT management should be seen not as an expense but as an investment in operational stability. Companies that establish compliant systems from the start enjoy shorter audits, faster refunds, and uninterrupted Amazon operations.

Official Resources and Amazon Tools

For Amazon FBA sellers in France, reliable information is everything. French tax legislation evolves constantly, and outdated online guides are a common source of errors. Below is a list of verified, official resources every seller should rely on:

impots.gouv.fr – Official DGFiP tax portal; the Professionnels and TVA à l’importation à autoliquider sections include CA3 instructions, filing deadlines, and templates.
bofip.impots.gouv.fr – The BOFiP database of official tax interpretations; key sections include BOI-TVA-DECLA, BOI-TVA-LIQ, and BOI-TVA-CHAMP.
douane.gouv.fr – Customs authority portal covering import, export, and ATVAI procedures.
Service des impôts des entreprises étrangères (SIEE) – The DGFiP unit handling foreign companies, based in Noisy-le-Grand.
Amazon Seller Central → VAT Resources (sellercentral.amazon.fr/help) – Amazon’s official guidance on VAT, EPR, and OSS compliance.
EU VIES (ec.europa.eu/taxation_customs/vies) – Tool for verifying EU VAT registration validity.
BOFiP / arrêté listings – The official, periodically updated lists of third countries exempt from appointing a fiscal representative.

Using these sources — and adhering strictly to your filing and payment schedules — will allow you to build a predictable, fully compliant tax structure for your French operations.

Final Takeaway

France may be an administratively demanding market, but for Amazon FBA sellers who master the TVA framework and invest in proper compliance, it is also one of the most profitable e-commerce destinations in Europe.

Treat VAT obligations not as a burden but as a strategic pillar of sustainable growth. The sooner you establish clean, compliant systems, the faster you can scale — free from the risk of penalties, account suspensions, or unexpected cash flow disruptions.

In the French VAT landscape, discipline is profitability — and the sellers who understand that principle are the ones who thrive.

Knowledge Base: E-commerce Accounting and VAT Compliance

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