1 Jan 2027 new date to reorganise and recodify VAT rules into new Consolidated Tax Code
- France has recodified its VAT legislation into the new Code de l’imposition sur les biens et services (CIBS), moving VAT rules out of the CGI and into a consolidated framework effective from 1 January 2027. This is a delay from the scheduled 1 September 2027.
- The reform restructures VAT provisions by sector, codifies key case-law principles, updates terminology, and directly incorporates mandatory EU VAT measures, including elements of the ViDA package.
- While largely a structural and drafting overhaul rather than a policy change, extensive transition rules apply, with continued reference to the CGI permitted until 31 December 2027 and e-invoicing rules remaining outside the CIBS for now.
France has reorganised and recodified its VAT legislation into a new Code de l’imposition sur les biens et services (CIBS). Ordinance No. 2025-1247 of 17 December 2025 formally transfers all VAT provisions out of the General Tax Code (CGI), with the new VAT framework low likely entering into force on 1 January 2027.
The reform does not fundamentally change how VAT operates in practice. Instead, it aims to modernise, rationalise and clarify the legislative structure governing VAT and other consumption taxes.
See more in our French VAT guide.
A consolidated framework for VAT on goods and services
The CIBS is intended to serve as a single legislative home for all taxes on goods and services. Its phased development reflects the breadth of this ambition, with excise duties, transport, digital and energy-related taxes already incorporated in earlier stages. VAT is the final major component to be integrated, completing a long-term restructuring project.
Clarity for VAT Provisions
Many articles have been simplified or shortened, the total number of provisions has increased, reflecting a more granular and systematic structure. VAT rules are now organised by sector of activity and grouped into a dedicated VAT “book” within the CIBS.
Special VAT regimes are treated as standalone sections rather than exceptions to the general regime, and reduced rates and exemptions are grouped by economic and sectoral category. Established case-law principles—such as the “direct and immediate link” test for input VAT deduction and the definition of a VAT permanent establishment—are now expressly codified.
Alignment with EU VAT law and updated terminology
The Ordinance directly transposes recent EU VAT directives into French law, including mandatory elements of the ViDA package and technical measures relating to the Import One-Stop Shop (IOSS). It also modernises VAT terminology and formalises key concepts, including categories of VAT exemption and the zero rate.
Phased transition from September 2026
The new VAT code applies with extensive transition measures. Taxpayers may continue to refer to former CGI articles until 31 December 2027, and existing administrative guidance remains valid. Notably, France’s upcoming e-invoicing mandate is unaffected and will be incorporated into the CIBS at a later stage.
