Important changes : Suspensive Tax schemes (RFSE or RFSI)

Foreign companies holding products under RFS status must be VAT registered in France.

What is a suspensive tax regime?

The RFSE or RFSI (Tax Suspension Scheme for Export or Import) allows foreign companies to buy, store and sell products under suspension of French VAT.
This regime, which is widely used in the wine and spirits industry, allows foreign operators not to pay VAT when they buy or sell products within the RFSE or RFSI stock.
This is assuming that the warehousekeepers offering this service have a specific customs authorisation and keep very precise accounts of the products they store with the Customs Administration.

What has changed in 2022:

The VAT aspects of this regime, previously managed by the Customs Administration, are now managed by the Tax Administration, which now requires that the operations known as "exits from suspensive regimes", i.e. the sales of products that come out of stock, be reported in a French VAT return.
Thus, companies holding stocks under the RFS regime and reselling their products to final customers in France, in the European Union or for export outside the EU, are required to:

  • Register for VAT in France through an accredited tax representative,
  • To file monthly VAT returns,
  • To file declarations of exchange of goods (also called Intrastat declarations) for sales to customers established in the European Union.

For companies that would exclusively sell to end customers from RFS stocks to European or non-EU customers, the use of a "one-off" or "global" representative is allowed.
These companies then use the tax identifiers of a one-off tax representative whose task is to report all transactions carried out by his customers to the French tax authorities through his "global" VAT number, as these customers are exempt from having their own VAT identification.
This solution, which is simpler than requesting a French VAT number, is however not allowed when sales are made to customers in France or if sales are made outside the RFS (for example from a "basic" warehouse).

What are the solutions proposed by

RMB has all the necessary accreditations from the French authorities to act as a fiscal representative for its foreign clients, whether it is to register them for VAT in France or to act as a one-off fiscal representative.

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