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Recodification of VAT provisions in the Code of Taxes on Goods and Services (CIBS): public consultation on an administrative ruling

Recodification of VAT provisions in the Code of Taxes on Goods and Services (CIBS): public consultation on an administrative ruling

Published on : 02/03/2026 02 March Mar 03 2026
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The tax authorities published, in the Official Public Finance Bulletin (BOFiP) of 18 February 2026 (BOI-RES-TVA-000253), a formal ruling concerning the legal and practical consequences of transferring the legislative VAT provisions from the General Tax Code (CGI) to the Code on Taxes on Goods and Services (CIBS), as enacted by Ordinance No. 2025-1247 of 17 December 2025.

This document is subject to a public consultation open until 15 April 2026.


1. A recodification at constant law… in principle

As from 1 September 2026, the legislative provisions relating to VAT will be fully codified within the CIBS. This reform forms part of a broader initiative aimed at rationalising and modernising the taxation of goods and services.

According to the tax authorities, this recodification is carried out “at constant law” (à droit constant), subject to limited exceptions.

In particular:
  • Administrative guidelines (BOFiP) and individual rulings based on the former provisions of the CGI will remain binding after 1 September 2026.
  • The regulatory provisions currently in force (notably those set out in the annexes to the CGI) will continue to apply until they are incorporated into the regulatory section of the CIBS.
  • The recodification will have no impact on the numerous taxes that refer to VAT for reporting or procedural purposes.

The authorities therefore emphasise the principle of legal continuity between the former and the new legislative framework.


2. Several noteworthy developments

Although the reform is presented as being at constant law, certain developments warrant particular attention:
  • Explicit incorporation of European Union case law into the legislative text;
  • Adjustment of jurisdictional rules relating to indirect taxation;
  • Technical reclassification of VAT suspension regimes as exemption regimes with the right to deduct input VAT;
  • Clarification of the rules governing the designation of the person liable for VAT on importation.

According to the tax authorities, these changes do not entail any substantive modification of taxpayers’ rights and obligations.


3. Operational impacts to be anticipated

While the substance of the rules remains unchanged, businesses will nevertheless need to take into account several practical developments.

a) A new legal architecture
The CIBS is structured around a thematic organisation and updated terminology. This new framework will require businesses, tax departments and practitioners to:
  • familiarise themselves with the new articles and numbering system;
  • update internal tools (document databases, procedures, etc.);
  • adapt legal and contractual analyses to the new references.

b) Invoicing and e-invoicing
The recodification does not affect either the timetable or the content of the electronic invoicing reform. The applicable rules remain unchanged in substance.

References to the CGI appearing on invoices may be maintained until 31 December 2027. After that date, companies will need to update their statutory references to reflect the new CIBS provisions.

This deadline requires anticipation of updates to:
  • invoice templates;
  • general terms and conditions;
  • commercial contracts;
  • and, more broadly, any legal documentation referring to CGI VAT provisions.


4. Public consultation open until 15 April 2026

The tax authorities expressly invite stakeholders to submit comments, in particular:
  • where there is doubt as to compliance with the principle of constant law;
  • regarding the entry-into-force arrangements;
  • or concerning any practical coordination difficulties.

This consultation represents an opportunity for companies and their advisers to anticipate areas of uncertainty and, where appropriate, secure their positions.


Implications for businesses

In summary:
  • This is not a substantive reform of VAT, but a major structural reform of the normative framework.
  • The transitional period (until 31 August 2026, and then until 31 December 2027 for certain references) should be used to adapt internal practices.
  • Particular attention should be paid to contractual documentation, invoicing processes and complex legal analyses.

Our firm assists companies in assessing the impact of this recodification and securing their tax positions.
 
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