VAT is the indirect tax that businesses encounter most. It seems mechanical in simple situations but becomes complex as soon as the business carries out international transactions, mixed transactions, exempt transactions or transactions falling under special schemes. A mistake in the VAT treatment can lead to a significant reassessment during a tax audit, together with late-payment interest and penalties.
We assist businesses in making their VAT treatment legally sound, resolving complex issues and defending their rights before the tax authorities.
Situations that call for a French VAT analysis
Some situations carry a particularly high VAT risk. Intra-Community transactions (supplies of goods and services between Member States of the European Union) are governed by place-of-supply rules that can be difficult to apply. Mixed transactions, carried out by partially taxable persons who make both taxable and exempt supplies, raise questions about the deduction ratio. Restructuring transactions (merger, contribution, sale) can trigger VAT adjustments on fixed assets. Sectors subject to special schemes (real estate, healthcare, financial services, agriculture) require a command of the specific rules that apply to them.
VAT audits in France
VAT receives particular attention during tax audits of accounts (vérifications de comptabilité). VAT reassessments often account for a significant share of the adjustments made during an audit. The most frequent points of friction concern the deductibility of VAT on mixed-use expenses, the treatment of credit notes and discounts, VAT on intra-group transactions, VAT on imports and intra-Community acquisitions, and VAT on international services.
We assist businesses during audits covering VAT and draft replies to proposed tax adjustments.
VAT refund claims
Businesses with a VAT credit can claim a refund. These claims are examined by the tax authorities, which can lead to audits and partial rejections. We assist businesses in preparing their claims and defending their rights if a claim is rejected.
Structuring complex transactions for VAT
Ahead of significant transactions (real estate investments, restructurings, complex legal structures), a VAT analysis makes it possible to optimise the applicable treatment within the legal framework and to prevent the risk of a later challenge.
See also our dedicated pages on the tax lawyer and the tax audit lawyer.
When to consult us
Before carrying out a transaction whose VAT treatment is uncertain. During a tax audit covering VAT. If a refund claim is rejected. When you want to assess your VAT exposure on recurring transactions.
Every situation is different: the information on this page is general and does not replace legal advice tailored to your case. The firm makes no promise of outcome; it commits to the means it deploys.
Related tax expertise
- Tax lawyer in Paris
- Personal tax lawyer
- Tax fraud lawyer in Paris
- Tax planning lawyer for company directors
- Lawyer for desk audits of accounts (examen de comptabilité) (in French)
Further reading
- Prior tax claim: how to challenge a tax before the tax authorities (in French)
- Tax appeal on points of law (pourvoi en cassation) before the Conseil d’État: conditions and procedure (in French)
- Requests for information from the tax authorities: how to respond
- Direct tax commission: when to be assisted by a tax lawyer (in French)
VAT grouping in France: the single taxable person
Since 1st January 2023, Article 256 C of the French General Tax Code (Code général des impôts, CGI) has allowed separate entities established in France to form a single taxable person (assujetti unique) for VAT purposes. The group is then treated as a single taxpayer: internal transactions fall outside the scope of the tax, and returns are filed by a representative appointed from among the members.
Three links must exist between the members – financial, economic and organisational – and they must be in place when the option is exercised and then continuously throughout the period covered. An entity can belong to only one single taxable person, and a single taxable person cannot be a member of another.
Who should consider the option?
It is of interest first to groups in which some members carry out an exempt activity and therefore bear non-deductible VAT on services received from other group entities. Neutralising internal flows removes this friction. It is also of interest to groups that want to simplify their filing obligations.
The choice is not neutral: the option is binding for a minimum period, it makes the members jointly liable for payment and it changes the calculation of the right to deduct at group level. It should be decided on the basis of a costed simulation, not on principle.
Official source
- Article 256 C of the French General Tax Code (Code général des impôts), single taxable person: Légifrance (in French)
Reference checked on 5 October 2026.
