Since January 1st, 2022, postponed VAT accounting (PVA) has been mandatory in France. That means all businesses registered for VAT in France pay their import VAT on their VAT return, rather than at the border.
Postponed VAT accounting (or autoliquidation de la TVA à l’import in French) is a system of handling import VAT. When you import something into France, you have to pay import VAT. Under PVA, you don’t pay it up front when you import something. Instead, you pay all the import VAT you owe via your VAT return.
The benefit of PVA is that it makes cash flow a lot easier to manage, especially if you’re a frequent importer. When you file your VAT return, you can offset your import VAT against the VAT you’ve collected on sales. That means in some cases, the money never leaves your account.
Some countries require a specific license or for you to appoint a fiscal representative to use PVA. In France, however, that’s not the case – it’s the default method for handling all import VAT.
Since January 2022, PVA has been mandatory in France. Prior to that, if you wanted to use PVA in France, you had to apply to the customs office to get authorisation. In our experience, this process wasn’t great. The time to get the application approved was never clear. It was hard to know when you’d need to apply to get authorisation in time for your import.
Now, all businesses registered for VAT in France use postponed VAT accounting by default. This makes it much easier, especially for businesses not based in France.
The system is called Autoliquidation de la TVA à l’import or ATVAI for short. When it’s time to file your French VAT return, you’ll find that the form has your import VAT amount pre-filled. You need to check that the amount is correct as part of the filing process. To make it easier to file your VAT return (the CA3), the customs authority (Douanes & Droits Indirects) creates a monthly statement of your imports. The statement is accessed through Données ATVAI, the online system.
When you ship goods to France under Import One Stop Shop (IOSS), you won’t need to worry about import VAT or PVA. IOSS is a VAT scheme designed to make things simpler for ecommerce businesses.
Once you’re registered for IOSS, you’ll get a unique IOSS number. You charge your customers VAT at checkout and file a monthly IOSS return. When you ship your customers their order, you securely pass your IOSS number to customs – usually via your shipping agent. Your IOSS number tells customs that you have already charged your customer VAT, and they release the parcel. No import VAT is charged at all.
It’s important to keep your IOSS number secure. If someone else uses your IOSS number to ship something, you’ll be liable for the VAT they should have charged on that order.
IOSS-registered sellers don’t need to worry about postponed VAT accounting in France. There’s no import VAT to handle, and you can’t reclaim VAT through an IOSS return.
Regime 42 is an EU customs procedure. Like Postponed VAT Accounting, Regime 42 moves the burden of import VAT. It allows non-EU businesses to import goods into the EU VAT-free if those goods are immediately bound for another EU state. The customer in the destination country uses the reverse charge mechanism to report the VAT. That means your customer will have to be VAT registered. For example, you sell machine parts to a company in Germany and ship them into the EU via France. Your customer reports the sale on their German VAT return using the reverse charge mechanism.
Using Regime 42 means that you (the seller) can import goods into a country without a VAT registration there. However, to work, you need to have a limited fiscal representative in the country where the goods enter the customs union. In the example above, you’d need a fiscal representative in France.
From the 31st of December 2025, France will no longer allow the use of Regime 42. Instead, you will have to either:
Making your customer the importer of record means that they are responsible for import VAT and duties. If you don’t want to do that, you will have to register for VAT in France. Rerouting isn’t a bad option either – the Netherlands is home to Europe’s largest port (Rotterdam) and is right next door. You’ll need to coordinate with your logistics partners to make this happen.
This blog was originally published 10th December 2021 and has since been updated for comprehensiveness.
