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VAT FOCUS n° 3 - Septembre 2006 (en anglais)

Reform of the VAT reverse charge mechanism in France.



As we mentioned in the two previous editions of ‘VAT focus’, the amended Finance Bill (LFR) for 2005 extended the scope of the VAT reverse charge mechanism. Now it is no longer the supplier, not established in France, but the purchaser of the goods and services, identified for VAT in France, who has to account for VAT through the reverse charge mechanism.

This new treatment will apply to the case of deliveries of goods in France and from France, deliveries after assembly and installation, services related to buildings located in France, cultural, artistic, sports, educational, entertainment and scientific services and all types of services other than those related to intra-community transport.

It is important to stress that the former rules remain the same, where the new regime is not applicable. Therefore, these provisions whose effect will generalize the reverse charge mechanism, are not intended to replace the "traditional" cases of reverse charge that already exist like, for example, those concerning intra-community acquisitions. So the latter will continue to apply under their own conditions with a specific VAT line and different VAT codes in the ERP.

Details of the new provisions

The new provisions, as presented by the LFR, have raised numerous questions concerning their application, as we already mentioned: should these provisions be considered as compulsory, what was the effect of a foreign supplier's French VAT number? Who had to pay VAT on imports in the case of sale with installation and assembly done by a supplier established outside the European Community?

The notice of June 23, 2006 resulting of discussions between the tax authorities, practitioners and professional organizations, has just provided answers to these issues.

These new provisions are compulsory. The principle now is that when the goods or services are delivered by suppliers or service providers not established in France, the VAT is paid by the client identified for VAT in France. Thus the client must account for VAT under the reverse charge mechanism, except in cases where the French Tax Code explicitly provides for a different taxable person or sets particular conditions.

Effects for the foreign suppliers

The effect of the new rules for the foreign supplier will be similar, whether or not the latter remains VAT registered in France (i.e. the VAT identification number of the foreign supplier has no ‘force of attraction’). The resulting treatment may be very difficult to define. As such, when a supplier of goods or services not established in France performs operations for French identified clients and operations for clients who are not identified for VAT in France:

- He may be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to French clients not identified for VAT in France ;
- He may not be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to companies identified for VAT in France;
- He may be VAT liable for operations not mentioned in the notice such as the rental of unfurnished offices not subject to the VAT option, imports.

Example:

It is important to stress again that the former rules remain the same, where the new regime is not applicable. Therefore a foreign supplier established in the UK but French VAT registered in France, will carry out seminar activities in France after September 1, 2006. The recipients of the seminar services will be French VAT identified clients, but also French clients who are not taxable persons and EU VAT identified clients. In that case, the foreign supplier will need to keep its VAT number in France:

- for EU VAT identified clients, the foreign supplier will still have to charge French VAT, through the French VAT identification ;

- for French but not taxable clients, the foreign supplier will have to charge French VAT, through the French VAT identification ;

- for French VAT identified clients, the foreign supplier should not have to apply French VAT even though he remains VAT identified in France. The French clients will have to account for VAT under the reverse charge mechanism.

However if the foreign supplier has only French clients identified for VAT in France, in that case the foreign supplier should cancel its French VAT number. Consequently the foreign supplier will have to invoice “with no VAT” his French clients identified in France, and the latter must apply the French VAT reverse charge mechanism.

Effects for the French companies (clients identified for VAT in France)

Symmetrically, for French companies (clients identified in France), posting of foreign supplier’s invoices is affected by the new provisions. A French company (client identified for VAT in France) should no longer be concerned by the fact that the supplier has an identification number or not in France. What is important is the exact type of supply of service or delivery of goods rendered. He must not totally rely on the VAT regime applied by the foreign supplier. Indeed because of the novelty and complexity of these texts, it is very likely that some foreign suppliers may also not apply the proper VAT regime. Indeed the French company (client identified in France) could receive, from a supplier established abroad (who may be French VAT identified or not), a wrong invoice with French VAT instead of an invoice with no French VAT, and the obligation for the client to account for VAT under the reverse charge mechanism. The fact that the supplier’s invoice quotes French VAT should not be considered as an indication that the right VAT regime was applied by the supplier.

Since the three penalties (detailed hereafter) could apply to the client in the case of application of an incorrect VAT regime by the foreign supplier or the client, it is important to check the relevance of the VAT regime applied before the invoice is posted.

Administrative tolerance

The new principle is adjusted by an administrative tolerance mentioned in the notice of June 2006. This tolerance does not change the liable person: the client who has a French VAT number is still the VAT liable person.

Nevertheless, when the supplier of goods or services and the client agree (most often they are two companies within the same group), the VAT legally due by the client is declared and paid by the seller in the name and on behalf of the client. For this purpose, the seller should designate a "guarantor"(1), a taxable person established in France, who will accomplish the declaration formalities and pay the VAT to the tax authorities on behalf of the seller. He has to be accredited by the competent tax authority. When the supplier of goods and services is not established within the European Community, the guarantor is the tax representative.

Due to this arrangement, in the same group it is possible to off-set the negative cash effects of the reverse charge mechanism for the seller: it can no longer charge the VAT collected on the sale to the VAT which it has to pay. The guarantor mechanism enables him to charge to the seller's declaration the tax which has to be paid by the purchaser of goods or services identified in France. Thus it reduces the amount of the seller's VAT credit. The notice also mentions particular cases in which this tolerance can apply(2).

(1) Freely translated from the French word “répondant”.
(2) Namely the case of importing followed by internal delivery; the purchase-resale in France of goods paid by a tax-payer established outside France, an intra-community acquisition (or equivalent transfer) followed by internal delivery in France done by a tax-payer established outside France, delivery of goods with assembly or installation done in France by a tax-payer not established in France.


Case of imports of goods followed by an internal delivery

These cases are particularly delicate since their treatment is different, although the hypotheses are similar. That is why they need to be explained in detail. The cases concerned here are deliveries of goods with assembly or installation carried out in France by a seller established outside the European Community for a French taxable person and the import of goods followed by an internal sale.

* In the first hypothesis, namely the delivery of goods with assembly or installation in France carried out by a seller established outside the European Community for a French taxable person, the notice of June did not mention any simplification as regards to VAT on imports to be paid by the seller. The seller has to identify itself in France in order to pay the import VAT, generating a tax credit that is deductible under the common conditions (13th VAT directive). The client established in France should account for VAT under the reverse charge mechanism on the subsequent internal delivery.

* In the second hypothesis, namely import of goods by a taxable person not established in France followed by internal delivery (with no assembly or installation), the VAT treatment of the import is totally different. It is possible that the VAT on the import is not paid by the foreign supplier but by the client identified for VAT in France if the latter is mentioned as the recipient on the import document (DAU) and if the goods are delivered directly to its premises. The client will then be exonerated from accounting for VAT under the reverse charge mechanism on the subsequent internal delivery.

Actions to be performed

September 1, 2006 is the deadline for the implementation of these new provisions.

Nevertheless a "tolerance" period, lasting until December 2006, has been unofficially granted by the tax authorities. The VAT return (CA 3) has been modified and two lines, 03B and 07A, have been added for the cases of reverse charge mechanism mentioned in the new provisions. These two lines should not be confused with line 03 which is to be used in the case of "classic" reverse charge mechanism.

* For a French company (client identified for VAT in France)

The notice recalls that failure to perform VAT reverse charge mechanism shall lead to a penalty of 5% in addition to which there is no deduction of the VAT incorrectly paid as well as late-payment interest due to non-payment of VAT. These three combined penalties are exclusively incumbent on the client identified in France and apply even if the error was committed by the foreign supplier. Under these circumstances, it is indispensable for companies identified for VAT in France to examine their flows and determine whether they become VAT liable persons when their supplier is a foreign taxable person. They have also to adapt their VAT returns and processes.

* For foreign suppliers

On their side, suppliers of goods and services who are not established in France must also identify their flows and determine whether they need to cancel their French VAT number.
They have also to adapt their invoicing process as well as ‘intrastat’ requirements.

* *
*

Finally, it should be noted that the anti-fraud measures introduced by France follow the current trend of the recent European directive of July 24, 2006 (2006/69/CE) aimed at fighting against fraud and tax evasion.

For the application of certain specifically mentioned provisions, this directive authorizes Member States to take all the steps necessary to prevent the application of these provisions making fraud or tax evasion possible. This system necessarily introduces divergences between the different legislations of Member States in terms of application of the provisions of the 6th VAT directive. This could make it more difficult to understand the different VAT systems transposed by the Member States and to implement VAT ERP processes in Europe.

Since the application of the new provisions introduced by the LFR is delicate, do not hesitate to contact our team. A hotline and training will be introduced in order to answer your questions.

Alain Recoules - Partner – 33 1 70 38 88 17
David Hirsch – 33 1 70 38 88 24
Aurélie Leprêtre – 33 1 70 39 43 53
 
VAT FOCUS n° 3 - Septembre 2006 (en anglais)
1 Septembre 2006
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Nevertheless a "tolerance" period, lasting until December 2006, has been unofficially granted by the tax authorities. The VAT return (CA 3) has been modified and two lines, 03B and 07A, have been added for the cases of reverse charge mechanism mentioned in the new provisions. These two lines should not be confused with line 03 which is to be used in the case of "classic" reverse charge mechanism.

* For a French company (client identified for VAT in France)

The notice recalls that failure to perform VAT reverse charge mechanism shall lead to a penalty of 5% in addition to which there is no deduction of the VAT incorrectly paid as well as late-payment interest due to non-payment of VAT. These three combined penalties are exclusively incumbent on the client identified in France and apply even if the error was committed by the foreign supplier. Under these circumstances, it is indispensable for companies identified for VAT in France to examine their flows and determine whether they become VAT liable persons when their supplier is a foreign taxable person. They have also to adapt their VAT returns and processes.

* For foreign suppliers

On their side, suppliers of goods and services who are not established in France must also identify their flows and determine whether they need to cancel their French VAT number.
They have also to adapt their invoicing process as well as ‘intrastat’ requirements.

* *
*

Finally, it should be noted that the anti-fraud measures introduced by France follow the current trend of the recent European directive of July 24, 2006 (2006/69/CE) aimed at fighting against fraud and tax evasion.

For the application of certain specifically mentioned provisions, this directive authorizes Member States to take all the steps necessary to prevent the application of these provisions making fraud or tax evasion possible. This system necessarily introduces divergences between the different legislations of Member States in terms of application of the provisions of the 6th VAT directive. This could make it more difficult to understand the different VAT systems transposed by the Member States and to implement VAT ERP processes in Europe.

Since the application of the new provisions introduced by the LFR is delicate, do not hesitate to contact our team. A hotline and training will be introduced in order to answer your questions.

Alain Recoules - Partner – 33 1 70 38 88 17
David Hirsch – 33 1 70 38 88 24
Aurélie Leprêtre – 33 1 70 39 43 53
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* In the first hypothesis, namely the delivery of goods with assembly or installation in France carried out by a seller established outside the European Community for a French taxable person, the notice of June did not mention any simplification as regards to VAT on imports to be paid by the seller. The seller has to identify itself in France in order to pay the import VAT, generating a tax credit that is deductible under the common conditions (13th VAT directive). The client established in France should account for VAT under the reverse charge mechanism on the subsequent internal delivery.

* In the second hypothesis, namely import of goods by a taxable person not established in France followed by internal delivery (with no assembly or installation), the VAT treatment of the import is totally different. It is possible that the VAT on the import is not paid by the foreign supplier but by the client identified for VAT in France if the latter is mentioned as the recipient on the import document (DAU) and if the goods are delivered directly to its premises. The client will then be exonerated from accounting for VAT under the reverse charge mechanism on the subsequent internal delivery.
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Nevertheless, when the supplier of goods or services and the client agree (most often they are two companies within the same group), the VAT legally due by the client is declared and paid by the seller in the name and on behalf of the client. For this purpose, the seller should designate a "guarantor"(1), a taxable person established in France, who will accomplish the declaration formalities and pay the VAT to the tax authorities on behalf of the seller. He has to be accredited by the competent tax authority. When the supplier of goods and services is not established within the European Community, the guarantor is the tax representative.

Due to this arrangement, in the same group it is possible to off-set the negative cash effects of the reverse charge mechanism for the seller: it can no longer charge the VAT collected on the sale to the VAT which it has to pay. The guarantor mechanism enables him to charge to the seller's declaration the tax which has to be paid by the purchaser of goods or services identified in France. Thus it reduces the amount of the seller's VAT credit. The notice also mentions particular cases in which this tolerance can apply(2).

(1) Freely translated from the French word “répondant”.
(2) Namely the case of importing followed by internal delivery; the purchase-resale in France of goods paid by a tax-payer established outside France, an intra-community acquisition (or equivalent transfer) followed by internal delivery in France done by a tax-payer established outside France, delivery of goods with assembly or installation done in France by a tax-payer not established in France.

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The notice of June 23, 2006 resulting of discussions between the tax authorities, practitioners and professional organizations, has just provided answers to these issues.

These new provisions are compulsory. The principle now is that when the goods or services are delivered by suppliers or service providers not established in France, the VAT is paid by the client identified for VAT in France. Thus the client must account for VAT under the reverse charge mechanism, except in cases where the French Tax Code explicitly provides for a different taxable person or sets particular conditions.

Effects for the foreign suppliers

The effect of the new rules for the foreign supplier will be similar, whether or not the latter remains VAT registered in France (i.e. the VAT identification number of the foreign supplier has no ‘force of attraction’). The resulting treatment may be very difficult to define. As such, when a supplier of goods or services not established in France performs operations for French identified clients and operations for clients who are not identified for VAT in France:

- He may be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to French clients not identified for VAT in France ;
- He may not be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to companies identified for VAT in France;
- He may be VAT liable for operations not mentioned in the notice such as the rental of unfurnished offices not subject to the VAT option, imports.

Example:

It is important to stress again that the former rules remain the same, where the new regime is not applicable. Therefore a foreign supplier established in the UK but French VAT registered in France, will carry out seminar activities in France after September 1, 2006. The recipients of the seminar services will be French VAT identified clients, but also French clients who are not taxable persons and EU VAT identified clients. In that case, the foreign supplier will need to keep its VAT number in France:

- for EU VAT identified clients, the foreign supplier will still have to charge French VAT, through the French VAT identification ;

- for French but not taxable clients, the foreign supplier will have to charge French VAT, through the French VAT identification ;

- for French VAT identified clients, the foreign supplier should not have to apply French VAT even though he remains VAT identified in France. The French clients will have to account for VAT under the reverse charge mechanism.

However if the foreign supplier has only French clients identified for VAT in France, in that case the foreign supplier should cancel its French VAT number. Consequently the foreign supplier will have to invoice “with no VAT” his French clients identified in France, and the latter must apply the French VAT reverse charge mechanism.

Effects for the French companies (clients identified for VAT in France)

Symmetrically, for French companies (clients identified in France), posting of foreign supplier’s invoices is affected by the new provisions. A French company (client identified for VAT in France) should no longer be concerned by the fact that the supplier has an identification number or not in France. What is important is the exact type of supply of service or delivery of goods rendered. He must not totally rely on the VAT regime applied by the foreign supplier. Indeed because of the novelty and complexity of these texts, it is very likely that some foreign suppliers may also not apply the proper VAT regime. Indeed the French company (client identified in France) could receive, from a supplier established abroad (who may be French VAT identified or not), a wrong invoice with French VAT instead of an invoice with no French VAT, and the obligation for the client to account for VAT under the reverse charge mechanism. The fact that the supplier’s invoice quotes French VAT should not be considered as an indication that the right VAT regime was applied by the supplier.

Since the three penalties (detailed hereafter) could apply to the client in the case of application of an incorrect VAT regime by the foreign supplier or the client, it is important to check the relevance of the VAT regime applied before the invoice is posted.
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This new treatment will apply to the case of deliveries of goods in France and from France, deliveries after assembly and installation, services related to buildings located in France, cultural, artistic, sports, educational, entertainment and scientific services and all types of services other than those related to intra-community transport.

It is important to stress that the former rules remain the same, where the new regime is not applicable. Therefore, these provisions whose effect will generalize the reverse charge mechanism, are not intended to replace the "traditional" cases of reverse charge that already exist like, for example, those concerning intra-community acquisitions. So the latter will continue to apply under their own conditions with a specific VAT line and different VAT codes in the ERP.
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September 1, 2006 is the deadline for the implementation of these new provisions.

Nevertheless a "tolerance" period, lasting until December 2006, has been unofficially granted by the tax authorities. The VAT return (CA 3) has been modified and two lines, 03B and 07A, have been added for the cases of reverse charge mechanism mentioned in the new provisions. These two lines should not be confused with line 03 which is to be used in the case of "classic" reverse charge mechanism.

* For a French company (client identified for VAT in France)

The notice recalls that failure to perform VAT reverse charge mechanism shall lead to a penalty of 5% in addition to which there is no deduction of the VAT incorrectly paid as well as late-payment interest due to non-payment of VAT. These three combined penalties are exclusively incumbent on the client identified in France and apply even if the error was committed by the foreign supplier. Under these circumstances, it is indispensable for companies identified for VAT in France to examine their flows and determine whether they become VAT liable persons when their supplier is a foreign taxable person. They have also to adapt their VAT returns and processes.

* For foreign suppliers

On their side, suppliers of goods and services who are not established in France must also identify their flows and determine whether they need to cancel their French VAT number.
They have also to adapt their invoicing process as well as ‘intrastat’ requirements.

* *
*

Finally, it should be noted that the anti-fraud measures introduced by France follow the current trend of the recent European directive of July 24, 2006 (2006/69/CE) aimed at fighting against fraud and tax evasion.

For the application of certain specifically mentioned provisions, this directive authorizes Member States to take all the steps necessary to prevent the application of these provisions making fraud or tax evasion possible. This system necessarily introduces divergences between the different legislations of Member States in terms of application of the provisions of the 6th VAT directive. This could make it more difficult to understand the different VAT systems transposed by the Member States and to implement VAT ERP processes in Europe.

Since the application of the new provisions introduced by the LFR is delicate, do not hesitate to contact our team. A hotline and training will be introduced in order to answer your questions.

Alain Recoules - Partner – 33 1 70 38 88 17
David Hirsch – 33 1 70 38 88 24
Aurélie Leprêtre – 33 1 70 39 43 53
These cases are particularly delicate since their treatment is different, although the hypotheses are similar. That is why they need to be explained in detail. The cases concerned here are deliveries of goods with assembly or installation carried out in France by a seller established outside the European Community for a French taxable person and the import of goods followed by an internal sale.

* In the first hypothesis, namely the delivery of goods with assembly or installation in France carried out by a seller established outside the European Community for a French taxable person, the notice of June did not mention any simplification as regards to VAT on imports to be paid by the seller. The seller has to identify itself in France in order to pay the import VAT, generating a tax credit that is deductible under the common conditions (13th VAT directive). The client established in France should account for VAT under the reverse charge mechanism on the subsequent internal delivery.

* In the second hypothesis, namely import of goods by a taxable person not established in France followed by internal delivery (with no assembly or installation), the VAT treatment of the import is totally different. It is possible that the VAT on the import is not paid by the foreign supplier but by the client identified for VAT in France if the latter is mentioned as the recipient on the import document (DAU) and if the goods are delivered directly to its premises. The client will then be exonerated from accounting for VAT under the reverse charge mechanism on the subsequent internal delivery.
The new principle is adjusted by an administrative tolerance mentioned in the notice of June 2006. This tolerance does not change the liable person: the client who has a French VAT number is still the VAT liable person.

Nevertheless, when the supplier of goods or services and the client agree (most often they are two companies within the same group), the VAT legally due by the client is declared and paid by the seller in the name and on behalf of the client. For this purpose, the seller should designate a "guarantor"(1), a taxable person established in France, who will accomplish the declaration formalities and pay the VAT to the tax authorities on behalf of the seller. He has to be accredited by the competent tax authority. When the supplier of goods and services is not established within the European Community, the guarantor is the tax representative.

Due to this arrangement, in the same group it is possible to off-set the negative cash effects of the reverse charge mechanism for the seller: it can no longer charge the VAT collected on the sale to the VAT which it has to pay. The guarantor mechanism enables him to charge to the seller's declaration the tax which has to be paid by the purchaser of goods or services identified in France. Thus it reduces the amount of the seller's VAT credit. The notice also mentions particular cases in which this tolerance can apply(2).

(1) Freely translated from the French word “répondant”.
(2) Namely the case of importing followed by internal delivery; the purchase-resale in France of goods paid by a tax-payer established outside France, an intra-community acquisition (or equivalent transfer) followed by internal delivery in France done by a tax-payer established outside France, delivery of goods with assembly or installation done in France by a tax-payer not established in France.

The new provisions, as presented by the LFR, have raised numerous questions concerning their application, as we already mentioned: should these provisions be considered as compulsory, what was the effect of a foreign supplier's French VAT number? Who had to pay VAT on imports in the case of sale with installation and assembly done by a supplier established outside the European Community?

The notice of June 23, 2006 resulting of discussions between the tax authorities, practitioners and professional organizations, has just provided answers to these issues.

These new provisions are compulsory. The principle now is that when the goods or services are delivered by suppliers or service providers not established in France, the VAT is paid by the client identified for VAT in France. Thus the client must account for VAT under the reverse charge mechanism, except in cases where the French Tax Code explicitly provides for a different taxable person or sets particular conditions.

Effects for the foreign suppliers

The effect of the new rules for the foreign supplier will be similar, whether or not the latter remains VAT registered in France (i.e. the VAT identification number of the foreign supplier has no ‘force of attraction’). The resulting treatment may be very difficult to define. As such, when a supplier of goods or services not established in France performs operations for French identified clients and operations for clients who are not identified for VAT in France:

- He may be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to French clients not identified for VAT in France ;
- He may not be VAT liable for deliveries of goods and services mentioned in the notice which are rendered to companies identified for VAT in France;
- He may be VAT liable for operations not mentioned in the notice such as the rental of unfurnished offices not subject to the VAT option, imports.

Example:

It is important to stress again that the former rules remain the same, where the new regime is not applicable. Therefore a foreign supplier established in the UK but French VAT registered in France, will carry out seminar activities in France after September 1, 2006. The recipients of the seminar services will be French VAT identified clients, but also French clients who are not taxable persons and EU VAT identified clients. In that case, the foreign supplier will need to keep its VAT number in France:

- for EU VAT identified clients, the foreign supplier will still have to charge French VAT, through the French VAT identification ;

- for French but not taxable clients, the foreign supplier will have to charge French VAT, through the French VAT identification ;

- for French VAT identified clients, the foreign supplier should not have to apply French VAT even though he remains VAT identified in France. The French clients will have to account for VAT under the reverse charge mechanism.

However if the foreign supplier has only French clients identified for VAT in France, in that case the foreign supplier should cancel its French VAT number. Consequently the foreign supplier will have to invoice “with no VAT” his French clients identified in France, and the latter must apply the French VAT reverse charge mechanism.

Effects for the French companies (clients identified for VAT in France)

Symmetrically, for French companies (clients identified in France), posting of foreign supplier’s invoices is affected by the new provisions. A French company (client identified for VAT in France) should no longer be concerned by the fact that the supplier has an identification number or not in France. What is important is the exact type of supply of service or delivery of goods rendered. He must not totally rely on the VAT regime applied by the foreign supplier. Indeed because of the novelty and complexity of these texts, it is very likely that some foreign suppliers may also not apply the proper VAT regime. Indeed the French company (client identified in France) could receive, from a supplier established abroad (who may be French VAT identified or not), a wrong invoice with French VAT instead of an invoice with no French VAT, and the obligation for the client to account for VAT under the reverse charge mechanism. The fact that the supplier’s invoice quotes French VAT should not be considered as an indication that the right VAT regime was applied by the supplier.

Since the three penalties (detailed hereafter) could apply to the client in the case of application of an incorrect VAT regime by the foreign supplier or the client, it is important to check the relevance of the VAT regime applied before the invoice is posted.
As we mentioned in the two previous editions of ‘VAT focus’, the amended Finance Bill (LFR) for 2005 extended the scope of the VAT reverse charge mechanism. Now it is no longer the supplier, not established in France, but the purchaser of the goods and services, identified for VAT in France, who has to account for VAT through the reverse charge mechanism.

This new treatment will apply to the case of deliveries of goods in France and from France, deliveries after assembly and installation, services related to buildings located in France, cultural, artistic, sports, educational, entertainment and scientific services and all types of services other than those related to intra-community transport.

It is important to stress that the former rules remain the same, where the new regime is not applicable. Therefore, these provisions whose effect will generalize the reverse charge mechanism, are not intended to replace the "traditional" cases of reverse charge that already exist like, for example, those concerning intra-community acquisitions. So the latter will continue to apply under their own conditions with a specific VAT line and different VAT codes in the ERP.

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