TLDR: International agreements influence the reporting of digital platform income in France by imposing declarative obligations on platform operators for sellers and service providers who are tax residents in France, the EU, or states with automatic exchange of information agreements. Platforms must report transactions of sellers and providers, except in specific cases, and follow designated procedures for reporting and correcting information.
Scope of international agreements
International agreements affect the reporting of digital platform income in France when transactions involve digital platforms and sellers or service providers residing in states with which France has signed automatic exchange of information agreements. Digital platforms, whether French, European, or non-European, must report transactions of sellers or service providers who are tax residents in France, another EU Member State, or a third country with which France has an automatic exchange agreement. This obligation arises from Article 1649 ter A of the French Tax Code (Code Général des Impôts, CGI) and applies to all transactions carried out from January 1, 2023.
Obligations of digital platforms
Registration and identification
Foreign platforms must register with the Direction Générale des Finances Publiques (DGFiP) before beginning to report transactions. Registration is done exclusively online by sending an email to france.aeoi@dgfip.finances.gouv.fr and providing the following information:
- Name and address (postal and electronic) of the platform.
- Tax identification numbers, including EU VAT codes.
- Details of registration under the non-EU OSS (One-Stop Shop) scheme, if applicable.
Data to be reported
Platforms must submit aggregated data per calendar quarter for each seller or service provider, including:
- Identification information: name, state or territory of tax residence of the seller/provider.
- Economic data:
- Net amount of consideration received (net of commissions, taxes, and delivery fees, if borne by the seller).
- Total number of transactions carried out during the quarter.
- Banking data: IBAN of the account to which payments are credited, if different from the seller's.
Deadlines and reporting methods
The declaration of transactions must be submitted by January 31 of the year following the year in which the transactions were carried out. For example, 2023 transactions must be reported by January 31, 2024. Transmission is exclusively electronic, via the DGFiP's dedicated platform. No paper-based method is provided for the initial declaration. Any corrections must be submitted from March 30 of the following year (N+1) and as soon as possible after detecting the error.
Tax treatment for self-employed workers
Self-employed individuals who earn income through digital platforms must report it in France if they are tax residents there. For income from states with which France has a double taxation convention, the foreign tax credit is applicable up to the lesser of the tax actually paid abroad (or the reduction provided for in the convention) and the French tax corresponding to the income earned abroad. In the absence of a convention, foreign income is taxed in France on the total net amount, with no possibility of a tax credit.
Exemptions and limitations
Non-EU resident platforms are exempt from reporting in France if:
- Their state of residence has an automatic exchange of information agreement with France recognized as equivalent to DAC 7.
- The transactions fall within the scope of this agreement and have already been reported in the platform's state of residence.
This exemption does not apply to platforms based in privileged states (e.g., tax havens) or in countries with which France has no tax cooperation agreements.