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Reverse Charge & “Call Off Stock” in France

  • Under the reverse charge mechanism, the supply of services provided by a non-established business to a French VAT registered business, the recipient, is taxed in France (recipient’s place of establishment). The recipient will collect and deduct VAT on the same VAT return.
  • Call-off Stock: Based on a business arrangement, a seller moves inventory to a customer’s location. The customer then uses these goods as needed, typically integrating them into a manufacturing process. Ownership transfers from the seller to the customer only when the goods are taken out of stock.

Read more about reverse charge and “Call-off stock” in France in our comprehensive guide.

Call-off stock in France

Consignment Stock:

In a consignment stock scenario, a supplier transfers their goods to a customer’s location in France. The buyer in France only acquires ownership of these goods when they are subsequently sold in their original state to other parties.

Call-off Stock:

Here, under a business agreement, a seller relocates inventory to a customer’s site. The customer utilizes these items as required, often incorporating them into a manufacturing workflow. Ownership only shifts from the seller to the customer when the items are withdrawn from stock.

In the French context, both “Consignment stock” and “Call-off stock” share identical VAT responsibilities.

Regulations:

Under the standard system, if goods are shipped or moved from another EU Member State to France on behalf of a taxable entity and stored before being bought by the latter, the supplier is considered to have made an intra-community acquisition in France that is subject to VAT. When the customer in France eventually takes ownership, this supply by the initial supplier is also taxable. Since the supplier is not based in France, the VAT is covered by the purchaser registered for VAT in France, using the reverse charge mechanism.

Since January 1st, 2020 (“2020 Quick Fixes”), there has been a simplified scheme. The new regime is not optional, but mandatory if the conditions for its application are met. The intra-community transfer of goods under this scheme is not treated as an intra-community supply, nor as an intra-community acquisition, under certain conditions. Taxation is deferred until the time of transfer of ownership. However, the business is not exempt from all obligations, since it must keep a register of the goods transferred and ensure that the goods concerned are indeed acquired by the recipient within 12 months. If the conditions are not fulfilled, the normal scheme will apply.

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France – Reverse Charge

Under the reverse charge mechanism, the supply of services provided by a non-established business to a French VAT registered business, the recipient, is taxed in France (recipient’s place of establishment). The recipient will collect and deduct VAT on the same VAT return.

 

 Domestic Reverse Charge

In France, the Domestic Reverse Charge mechanism is used to prevent tax evasion in specific types of transactions. Under this system, the buyer, rather than the supplier, is responsible for accounting and paying the VAT to the tax authorities.

 

The following transactions are subject to the Domestic Reverse Charge in France:

  • Deliveries of gold in the form of raw material or semi-finished products if they meet certain requirements. However, the seller remains jointly liable for the VAT.
  • Supplies of natural gas and electricity, as well as certain related networking services, if the buyer has a French VAT identification number and is based in France.
  • Supplies of industrial waste and recovery materials, as well as related services, if the recipient or lessee has a French VAT identification number.
  • Sale of greenhouse gas emission rights.
  • Certain electronic communications services.

 

 

Last Updated: 27/10/2023

Disclaimer

The information provided by Global VAT Compliance B.V. on this webpage is intended for general informational purposes only. Global VAT Compliance B.V. is not responsible for the accuracy of the information on these pages, and cannot be held liable for claims or losses deriving from the use of this information. If you wish to receive VAT related information please contact our experts at support@gvc.tax

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