Current exempt list (2026)
As of 2026, the jurisdictions most commonly accepted by the French tax authority as having the required mutual-assistance footprint, and therefore exempt from the VAT representative rule, are the following: the United Kingdom, Norway, Iceland, Liechtenstein, Switzerland, San Marino, the Faroe Islands, Greenland, Mexico, Saint-Barthélemy (for its specific status), and a small set of further states covered by case-specific agreements. The list evolves; the DGFiP publishes updates through BOFiP notes referenced under Article 289 A CGI. Treat this page as a working view and confirm the current text of the BOFiP note before you sign a mandate, especially if your jurisdiction is near the edge, such as a Commonwealth country that has recently signed a tax-cooperation treaty.
How a country gets on the list
The test is not whether the country has a VAT system or a double-taxation treaty with France. The test is whether the country has a mutual-assistance instrument that lets the French Treasury recover VAT receivables across the border without going through a representative. That instrument can take three forms. First, a bilateral tax-cooperation and recovery treaty with France covering VAT. Second, a multilateral convention such as the OECD Convention on Mutual Administrative Assistance in Tax Matters, where both parties have signed and the recovery chapter is in force. Third, a specific post-Brexit protocol, such as the arrangement covering the United Kingdom. The distinction matters because many companies point to the income-tax treaty and assume VAT is covered; it usually is not. Check the recovery chapter, not just the treaty title.
Commonly confused: who is not exempt
The jurisdictions most often assumed to be exempt, and are not, fall into four families. The Crown Dependencies, Jersey, Guernsey, and the Isle of Man, are separate from the UK for tax treaties and remain outside the reciprocity list. The British Overseas Territories, Gibraltar, Bermuda, the Cayman Islands, are in the same position. The Gulf states, the United Arab Emirates, Saudi Arabia, Qatar, Kuwait, Bahrain, Oman, all have strong tax-cooperation treaties on income but the VAT recovery chapter has not been activated for French purposes. The major Asian trading partners, Singapore, Hong Kong, Japan, South Korea, are also outside, despite deep French trade flows. A non-EU company established in any of these jurisdictions and generating a French VAT liability needs a French fiscal representative, full stop.
EEA status and the EU VAT zone, briefly
The European Economic Area overlaps with the exempt list but is not the same set. Norway, Iceland, and Liechtenstein are in the EEA and are on the exempt list; they are, however, outside the EU VAT zone, which means a representative is not required but direct French VAT registration is. The confusion is understandable: operationally, these three feel like EU members for services and goods coordination. Legally, they are third countries with a mutual-assistance treaty strong enough to override the representative rule. The distinction changes nothing day to day but it changes the paper trail, particularly for triangulation and distance selling.
Worked example
A Norwegian industrial supplier plans to invoice €2.4 million of equipment to a French customer in 2026, with installation services in Lyon. The question is whether a French VAT fiscal representative is required. Norway is on the exempt list, so the answer is no. The Norwegian company registers directly with the SIEE in Noisy-le-Grand, obtains a French VAT number, charges French output VAT on the installation service component, and claims input VAT on local French subcontractors. Compared with the mandatory regime, the company saves a representative fee band of roughly €8,000 to €15,000 per year, plus a deposit that would have sat idle. Now replace the Norwegian parent with a Singaporean one and the answer flips: Singapore is not exempt, a representative is required, and the first-year cost jumps by that same fee band plus the deposit.
Pitfall to avoid
The pitfall is trusting a partner brochure over the BOFiP note. Firms selling VAT representative services have, unsurprisingly, an interest in reading the exempt list narrowly; their sales materials occasionally describe a country as non-exempt when the DGFiP note plainly says otherwise. The opposite can also happen: a compliance desk inside a large group decides a country must be exempt because an income-tax treaty exists, and quietly skips the representative when one is required. Resolve both failure modes the same way: open the current BOFiP note, read it, and save it as a PDF in the file before you sign anything.
Pro tip
If your jurisdiction has just signed a mutual-assistance instrument with France, do not assume the exemption is already active. The French administration takes a few months to issue the updated BOFiP note, and customs clearance software at Le Havre will not recognise the change until the note is published and the internal fiscal reference codes are updated. File a short letter to the SIEE asking for confirmation of the applicable regime on the effective date; the reply doubles as an audit shield if the firm registers directly and is later challenged. Treat the letter as a standard operating procedure for the first six months of any new exempt status.
Key takeaways
- Exempt list for 2026: UK, Norway, Iceland, Liechtenstein, Switzerland, San Marino, the Faroes, Greenland, Mexico, plus case-specific others.
- Confirm the BOFiP note under Article 289 A CGI before signing; the list is administrative and shifts.
- Crown Dependencies, Overseas Territories, Gulf states, and major Asian hubs are not exempt.
- EEA status overlaps the exempt list but is not the same set; direct French VAT registration is still required.
- Income-tax treaty existence does not imply VAT recovery coverage; check the recovery chapter.
Frequently asked questions
Where is the official exempt-country list published?
The Direction Générale des Finances Publiques publishes and refreshes the list through administrative notes in the BOFiP database under the TVA section covering Article 289 A CGI. The list is not in the Code itself; that is why it shifts over time as new agreements enter into force.
Is Gibraltar on the list?
No. Gibraltar is outside the UK for VAT purposes and has no mutual-assistance agreement with France for VAT recovery. A Gibraltar-established company selling into France will need a French VAT fiscal representative.
Does a Swiss holding with a French branch need a representative?
No for the Swiss side, because Switzerland is on the exempt list. The French branch itself is established in France and therefore outside the non-EU rule entirely. If the French branch is acting, no representative question arises; if the Swiss parent acts directly on French flows, the Swiss exempt status covers it.
What happens if a country joins the exempt list mid-year?
The exemption takes effect on the date stated in the DGFiP note, usually the first day of the month following publication. Mandates already signed remain valid for the declaration periods they covered; new flows from the effective date can be handled by direct registration.