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France tightens IOSS Intermediary rules

France moves to close shell Intermediary representatives

France is to enforce new requirements for Intermediaries – a type of Fiscal Representative – for the new Import One-Stop Shop IOSS returns introduced on 1 July 2021 as part of the EU e-commerce package.

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Intermediaries are EU-resident VAT representatives for non-EU sellers or deemed supplier marketplaces who are reporting monthly IOSS filings for import consignments not exceeding €150. They must ensure returns are submitted on time and are accurate, and are the first point of call for the EU authorities. In a number of EU states, Intermediaries are held joinly and severally liable for the sellers or marketplaces obligations.

2022 Finance Bill Intermediary tests

The French 20222 Finance Bill imposes additional new criteria on Intermediaries filing IOSS returns. These include:

  • Can demonstrate genuine staffing and business processes to support IOSS filings
  • Can show at financial resources to support at least one quarter’s VAT liablities based on its estimated client liabilities.
  • A clean tax compliance and solvency record


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