Changing Your French VAT Provider: Handover Checklist

A French VAT registration belongs to the foreign company. The number is FR, a two-digit key and the company's SIREN, as the identifier guide explains, which is why a change of adviser does not by itself create a new number. If the legal entity and the taxable activity stay the same and the registration is still open, the number normally continues. What moves is the authority to act: the mandate given to a filing agent, or the accredited fiscal representation for a business that must have one.

Two situations are registration questions rather than handover questions and belong in the registration guide: a different legal entity is now selling into France, or the tax office has closed the registration. Check the current position on the professional tax account before anyone promises continuity.

The table below sets out the three setups a foreign company can be in and what physically changes hands in each. The fiscal representative is required for companies established outside the EU and outside the countries listed by the order of 15 May 2013; the exempt-countries guide covers that list, so this article does not repeat it.

Start with a list of everything that identifies the company in France and everything that lets someone act for it. Most handover disputes come from an item that nobody listed: an EDI partner still filing under the old instruction, a professional tax account created under a former employee's e-mail, or a mandate whose effective date nobody can find.

The single most useful handover document is a period-by-period statement of what was filed, what was paid and what the tax office shows. Filed and paid are different facts. DGFiP explains that a rectifying return cancels and replaces the return for its period but does not cancel the payments already made, so a corrected period can leave a credit or a balance that only the tax account reveals.

For every period, collect the filed CA3 with its acknowledgement, the payment evidence and the tax account's view of that period. Where a credit was carried forward, follow it from line 27 of one return to line 22 of the next, as the CA3 guide describes line by line.

Balances are not corrections. A credit that the tax account confirms is a balance. A period where the outgoing provider knows the figures were wrong is a pending correction, and it needs its own row on the worksheet, its own owner and its own date.

Use one row per record and per period. The columns are deliberately operational: they force the two providers to name who holds each item, what evidence has actually changed hands and what remains open. The first row is a completed example. It is illustrative and not a client case; the dates follow the SIEE monthly calendar described in the CA3 guide.

The changeover period has one owner. For a mandataire, the answer follows the mandate: DGFiP states that the new mandate applies from acceptance by the parties, that the previous mandate lapses and that only the new mandataire may then act, and it asks to be informed as soon as possible by e-mail to the SIEE with the new mandate attached. Fix the acceptance date so that it falls between two filing deadlines, send that e-mail, and record which of the two providers files the return that straddles the change.

For an accredited fiscal representative the dates matter more, because liability follows the designation. BOFiP states that the representative answers for the represented business's VAT for the whole period during which its designation is valid; that a representative giving up the role must do so in writing to both the business and the tax office, with no effect before the office has been notified; and that the designation is made before the operations it covers, states its effective date and is in principle not retroactive.

In both cases, write the allocation down: the last period filed by the outgoing provider, the first period filed by the incoming one, and who handles anything that lands in between. The transfer service documents exactly these two periods before taking over.

Missing records are common when the relationship with the outgoing provider has soured. Filed returns and the account position can be reconstructed from the professional tax account, and the invoices, ledgers and marketplace reports belong to the company, so rebuild from those rather than waiting for the provider. Ask for the complete files in writing all the same, and keep the request with the handover evidence.

A deadline that falls during the transfer is met on time by whoever holds the authority on that date, with the best data available. If the figures later prove wrong, a rectifying return for the same period cancels and replaces the initial return without cancelling the payments already made. When the correction reduces the VAT due, DGFiP's guidance is to recover the overpayment through a claim sent from the secure messaging of the professional tax account, not by paying less the next time.

Do not skip a period because the provider is changing. Monthly and quarterly businesses managed by the SIEE file a nil CA3 when there is nothing to declare, and a missing return is the first thing a new provider inherits.

A credit belongs to the company, not to the provider. It is either carried forward on the next return or claimed back. DGFiP states that a refund of a VAT credit is requested electronically on form 3519 from the professional tax account and that the electronic route applies to every business. Decide which of the two options applies before the first new return, and record on the worksheet who submits the claim and against which evidence.

A debt is a payment question first and a liability question second. Agree who pays what is already due, keep the payment evidence with the returns, and remember that under fiscal representation the representative designated for the period remains answerable for it. A debt that comes from an error is a correction, and correction work is scoped separately from the handover; where the tax office is already asking questions, the audit-support service takes that thread.

The first filing under the new engagement is agreed in writing before any authority is transferred: the period, the deadline, who prepares, who approves and who pays. Everything before that period is handed over as complete, listed as a pending correction, or excluded.

Then define the scope of the engagement itself, because 'French VAT' can mean very different things. A filing engagement prepares and submits the CA3 from data the client approves. Fiscal representation adds the statutory role and its liability. Neither automatically covers e-reporting preparation, OSS returns, customs questions or the response to a tax audit; those are separate services with separate evidence.

The short answers below carry the caveats that matter. None of them replaces a check of the company's own tax account, because the account, not the provider, is the record the tax office works from.

Five situations need a decision rather than a worksheet row. Each one has a next step that does not depend on the outgoing provider.