Foreign company managed from France: VAT and corporate tax obligations

Why the place of management matters

A company is not taxed only where its registered office is. Tax authorities also look at where the business is really run: where key decisions are taken, where the directors live and work, and where the activity is organised. A company registered in another country but managed from France can therefore find that France considers it has taxable presence here, even without an office or employees.

This situation is common among small international groups, start-ups and holding or service companies whose director lives in France. It does not mean the company is doing anything wrong. It means the French rules need to be checked early, before a tax office raises the question for you.

What points to management from France

There is no single test. The authorities look at the facts as a whole. The following points are typically examined:

• the director or managing director lives and works in France;
• key decisions, such as contracts, pricing, hiring and investments, are taken from France;
• board meetings or approvals take place in France, or by video from France;
• the company has no real premises, staff or decision-makers in its country of registration;
• customers, suppliers or the bank deal with the company through a person based in France;
• the company works mainly for customers or group companies in France.

Consequences for VAT

For VAT, the place where a business is established is the place where its economic activity is carried out, and the place where key management decisions are taken is one of the criteria looked at. A company managed from France may therefore be treated as established in France for VAT, which can change:

• who must charge VAT on its supplies, and at which rate;
• where and how it registers, and which tax office handles its file;
• whether its customers can reverse-charge the VAT;
• the VAT returns and intra-EU declarations it must file.

If your company has to register, read our guide to France VAT registration for foreign companies. To understand who can act for you, see our guide to the French VAT agent.

Consequences for corporate tax

French corporate tax applies in principle to profits from a business carried on in France. A foreign company run from France may be considered to carry on a business here, or to have a permanent establishment in France. The outcome depends on the facts and, where there is one, on the tax treaty between France and the country of registration, which has rules to avoid double taxation.

If the company has French corporate tax obligations, it generally has to register and file returns. See our page on corporate tax registration in France.

What to check before you act

1. Map the facts: who decides what, where, and who can prove it.
2. Identify the countries involved: country of registration, country of residence of the directors, countries of customers.
3. Review VAT: established in France or not, and which registration, if any, is needed.
4. Review corporate tax: possible French taxable presence and the applicable treaty.
5. Decide the route: register in France, restructure the management, or document why the company is not managed from France.
6. Keep the documents: board minutes, contracts, travel and meeting records.

Our quick check gives a first idea of which French obligations may apply to you.

Common mistakes

• Assuming a registered office abroad is enough to avoid French taxes.
• Registering for VAT in France without checking the corporate tax position, or the reverse.
• Waiting for a tax office letter before looking at the question.
• Changing the structure without checking its tax effects first.
• Relying on a single point, such as the director’s residence, instead of reviewing the full picture.

FAQ

Informational content, which does not constitute legal advice. The rules that apply depend on your situation. Last updated: October 2026.