Every VAT-exempt intra-EU supply of goods must be reported on the VAT recapitulative statement, filed monthly. This statement, which took over the tax part of the former DEB, allows European tax authorities to cross-check their information.
For a foreign company with a VAT registration in France, a mistake may look harmless; yet it can call the exemption itself into question. Here are the points to watch.
Why this statement is decisive
Since the 2020 EU reforms, the exemption of an intra-EU supply depends on two conditions: a valid VAT number for the customer, and the correct reporting of the transaction on the recapitulative statement.
An unjustified omission may lead the tax authorities to refuse the exemption and claim French VAT on the sale. The risk therefore goes beyond a mere reporting formality.
The mistakes that cost you
- An invalid or wrong customer VAT number: it must be checked before invoicing, for example on the EU VIES system.
- Amounts that do not match the intra-EU supplies reported on the CA3.
- A transaction attached to the wrong period, because the right tax point rule was not applied.
- Forgotten stock transfers between your own warehouses located in different Member States.
- Confusion with the EMEBI, a separate statistical return with its own rules and thresholds.
Mistake, consequence, fix
| Mistake | Risk | Fix |
|---|---|---|
| Invalid VAT number | Exemption refused, French VAT claimed | Check before invoicing, keep proof |
| Gap with the CA3 | Request for information | Monthly reconciliation of both returns |
| Wrong period | Return to be corrected | Apply the appropriate tax point rule |
| Stock transfer omitted | Failure to report | List movements between warehouses |
Preparing the monthly filing
A reliable statement is built upstream, at invoicing. A few simple habits sharply reduce the risk of error:
- keep a customer file with the intra-EU VAT number and the date of the last check;
- keep, for each supply, the documents proving the goods were transported to another Member State;
- separate in your accounts exempt supplies, taxable sales in France and stock transfers;
- set an internal monthly closing calendar so the statement is filed on time and reconciled with the CA3.
These checks matter even more for a European company new to French obligations, as invoicing practices vary from country to country. The exact supporting documents to keep depend on your situation and should be confirmed.
A monthly review routine that works
The most effective protection is a short, repeated routine rather than a large annual clean-up. Each month, before filing, walk through the same questions:
- Does every exempt intra-EU invoice carry a customer VAT number that was valid when the sale was made?
- Do the totals on the statement match the intra-EU supplies line of the CA3?
- Have all stock movements between Member States been identified and treated correctly?
- Are late credit notes or corrections reflected in the right period?
A foreign company often delegates part of this work to its bookkeeper or ERP. It remains useful to keep one person accountable for the final reconciliation, since the exemption and the related risks sit with the company that made the supply. Check the rules applicable to your case.
The consequences of a failure
Beyond the risk of losing the exemption, each omission or inaccuracy may be sanctioned by a fine. Inconsistencies between Member States are also a frequent reason for information requests, or even an audit.
The amount of penalties depends on the nature of the mistake and your situation and should be checked case by case. For an overview, see our article on VAT penalties, late-payment interest and surcharges.
How Hanoutax can help
Hanoutax, a French VAT agent acting as mandataire fiscal, checks your customers’ VAT numbers, prepares the recapitulative statement from your invoicing data, reconciles it with your VAT return and files it on time.
Learn more on our VAT recapitulative statement page and our EMEBI and DES service. Hanoutax acts as an agent; it is not a fiscal representative in France, a notion clarified on our fiscal representative France page.
FAQ
How often is the recapitulative statement filed?
It is filed monthly, for the VAT-exempt intra-EU supplies of goods of the period.
How do I check an EU customer’s VAT number?
Before invoicing, for example on the EU VIES system. Keep proof of that check.
Are the EMEBI and the recapitulative statement the same return?
No. The EMEBI is a separate statistical return with its own rules and thresholds.
Must stock transfers be reported?
Transfers of stock between your own warehouses in different Member States are a frequently forgotten point of attention.
What is the risk if I make a mistake?
Refusal of the exemption with a claim for French VAT, a fine, or even an audit. Amounts depend on your situation.
Secure your intra-EU supplies
Related reading
Informational content, not legal advice. The rules that apply depend on your situation.
