TLDR: To invoice a non-EU client, apply VAT exemption if you prove the goods were exported or services performed outside the EU. Keep customs documents and include specific details on the invoice. If you are based outside the EU, appoint a fiscal representative in France.
When VAT Exemption Applies
VAT exemption applies to sales of goods shipped or transported outside the EU, whether transport is arranged by the seller or the non-EU buyer. For services, exemption only covers the portion performed outside the EU if the service is singular and the client is non-EU. Exemption does not apply to goods intended to equip private means of transport.
Obligations for Non-EU Freelancers: Fiscal Representative
If you are a freelancer not established in France but residing in a non-EU country, you must appoint a fiscal representative to fulfill VAT obligations in France. The representative must be explicitly stated on all issued invoices and acts as the liaison with the French tax authorities. This requirement does not apply to freelancers established in EU Member States.
Required Documentation for Exemption
Proof of export is essential to benefit from VAT exemption. Valid documents include:
- Electronic customs declaration via the Delt@ export system,
- Paper DAU document stamped by customs,
- Transport documents to a non-EU country,
- Postal documents stamped by the postal service,
- Declarations from the carrier or freight forwarder for operations under Incoterms EXW or FOB.
Mandatory Invoice Content
Invoices issued to non-EU clients must include specific details such as:
- Name and address of the fiscal representative (if applicable),
- Legal reference to VAT exemption,
- Detailed description of goods or services,
- Proof of export,
- Written commitment from the buyer to export goods outside the EU.
Supporting documents to retain include commercial contracts, client correspondence, customs documents, and carrier declarations.
Deadlines and Corrections
There are no specific deadlines for issuing invoices under VAT exemption for exports, but they must be issued by the 15th of the month following the service or delivery. If errors occur, issue a credit note and re-invoice with corrections.
Exceptions and Limits to Exemption
Exemption does not apply if:
- Goods are intended to equip private means of transport,
- Transport is arranged to another EU Member State,
- Proof of export is insufficient.
For finishing operations, the seller must obtain a written commitment from the buyer to export the goods outside the EU after processing.