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BOFIP – VAT: Overview of mandate and representation mechanisms for non-established taxable persons

BOFIP – VAT: Overview of mandate and representation mechanisms for non-established taxable persons

Published on : 08/12/2025 08 December Dec 12 2025
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In a ruling published in the BOFIP on 03/12/2025, the tax authorities reiterate the mandate and representation mechanisms applicable to a taxable person not established in France (in addition to mandatory fiscal representation):
  • Ad hoc agent (EU only): Available for certain exempt customs operations (imports followed by an intra-Community supply, release from suspension regimes). Only for EU operators.
  • Permanent agent: Available to all non-established taxable persons to outsource all or part of their reporting and payment obligations, under the principal’s responsibility.
  • International agent (in force since January 1, 2025): Allows non-established importers to appoint the operator with physical control of the goods, without accreditation or transfer of responsibility.
  • Occasional fiscal representation: Abolished, with an exceptional extension until December 31, 2025 for non-EU operators; the mechanism is permanently removed as of January 1, 2026.
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