The French Supreme Court reaffirmed that contractual arrangements determine the recipient of services for VAT purposes in the American Express case. It ruled that issuer commissions are considered services supplied to a non‑EU recipient, allowing the French entity to recover VAT on those commissions. The decision reinforces the importance of economic substance and contractual reality in VAT treatment.
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Vertex Inc. · 1 day ago
Vertex Inc. highlights how continuous transaction controls (CTCs) shift tax compliance into real-time, exposing risks from misaligned IT, tax, and finance functions. The article outlines upcoming EU e‑invoicing mandates—Belgium 2026, Slovakia 2027, France 2026, Poland 2026, Germany phased rollout—and stresses the need for cross‑functional collaboration to meet real‑time reporting requirements.
e-Invoice.app · 8 days ago
France’s e‑invoicing reform mandates all VAT‑subject businesses to use an approved platform from 1 September 2026, with SMEs joining in 2027. The article explains the difference between accreditation and live invoice exchange, outlines penalties, and highlights the possibility of a 1 December 2026 deferral.
Comarch · 10 days ago
France will enforce a comprehensive e‑invoicing and e‑reporting mandate from 1 September 2026. Large and intermediate‑sized companies must issue e‑invoices immediately, while SMEs and foreign firms begin on 1 September 2027. The guidance outlines size thresholds, real‑time reporting requirements, and the penalty regime during the pilot phase.
Storecove · 15 days ago
France has launched a 2026 e‑invoicing pilot that runs from February to August, allowing businesses to test real invoice exchanges on the French Public Invoicing Portal. The pilot precedes the mandatory e‑invoicing regime that will take effect on 1 September 2026. Storecove will enable clients to join the pilot from mid‑June via its French API and the national Annuaire directory.
VatCalc · 22 days ago
France confirms that its e‑invoicing mandate remains scheduled for 1 September 2026, with no postponement announced. The DGFiP will soften penalty enforcement until at least 1 January 2027 for taxpayers who made best efforts from the start of the first phase, and a contingency deferral to 1 December 2026 is still available. The launch will rely on the Plateforme Agréée network, of which only a fraction are currently active.
e-Invoice.app · 23 days ago
France's e-invoicing reform, effective 1 September 2026, requires all businesses with a French VAT footprint to use approved platforms for issuing and receiving electronic invoices and for transmitting transaction and payment data. The reform mandates structured invoice formats (UBL, CII, Factur-X) following EN 16931 with French extensions and adds four mandatory fields. SMEs and micro-enterprises will join the issuance and reporting obligations on 1 September 2027, while large enterprises must comply from 1 September 2026.
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Key Takeaways
It ruled that issuer commissions are considered consideration for services supplied to a non‑EU recipient, allowing the French entity to recover VAT on those commissions.
By treating issuer commissions as services to a non‑EU recipient, the ruling enables French entities to claim VAT deductions on those commissions, improving their VAT recovery ratio.
The Court relied on the principle that contractual terms must reflect the economic and commercial reality of the transaction, citing the CJEU Paul Newey judgment.
The improved VAT recovery from treating commissions as services to a non‑EU recipient can enhance the salaries tax position, as the tax depends on the proportion of turnover that allows VAT deduction.
Primary source
Read the full article at Bloomberg TaxThis summary was published on VATfaqs.com on 12 May 2026. It relates to VAT developments in France. The original source is Bloomberg Tax.
