Selling consulting, services or SaaS to France from outside the EU
Your company is based in the US, Canada, the UK or the Gulf and you invoice French clients for consulting, development or marketing. Under article 182 B of the French tax code, your client may have to withhold tax from what it pays you unless a tax treaty gives you better treatment, and France's e-invoicing reform has its own rules for sellers with no establishment there. This guide sets out each rule, who carries it and when, with a link to the official text.
What France asks of a non-EU service provider
Six rules, who carries them and when they apply.
| Obligation | Rule | Who | When or how long | Official source |
|---|---|---|---|---|
| Withholding on services | Standard corporate tax rate on fees for services supplied or used in France (25% in the 2022 BOFiP) | The French client that pays you | On each payment | CGI art. 182 B |
| Non-cooperative jurisdictions | Higher rate of 75% | The French payer, when you are established in a non-cooperative State or territory | On each payment | CGI art. 182 B |
| Paying the withholding | Form 2494-SD | The French payer | By the 15th of the month after the calendar quarter of payment | BOFiP, § 100 |
| Treaty relief | The withholding gives way to tax treaties | A provider resident in a treaty country claims it | Procedure to confirm with the payer | BOFiP, § 40 and § 95 |
| E-invoicing and e-reporting | No e-invoices to issue; e-reporting through an approved platform; the French buyer reports reverse-charged B2B sales | A foreign company with no fixed establishment in France | Reform from 1 September 2026 (large and intermediate-sized companies) and 1 September 2027 (SMEs and micro-businesses) | impots.gouv.fr |
| Digital services tax | 3% on targeted advertising and digital intermediation | Groups above EUR 750 million worldwide and EUR 25 million in France | Rate unchanged in the code as of 14 March 2026 | CIBS art. L453-45 and following |
The sections below take each line in turn. Rules and dates are those in the official sources as read on 6 November 2026.
Article 182 B: tax withheld by your French client
The French payer withholds the tax. You receive the fee minus that tax, unless a treaty gives you better treatment.
Article 182 B of the French general tax code (CGI) applies when a payer that carries on an activity in France pays a non-resident with no permanent professional installation in France for services of any kind supplied or used in France. The payer withholds tax from those sums. Consulting, development and marketing are all within its scope (CGI art. 182 B, BOI-IR-DOMIC-10-20-20-50).
The rate is the standard rate of corporate income tax. The tax authority's official commentary, the BOFiP, gives 25% in its 2022 version. When the provider is established in a non-cooperative State or territory, the rate rises to 75% (CGI art. 182 B). We have not re-read the rate for 2026 in an official source, so confirm it before you price a French contract.
Used in France is enough
The article covers services supplied or used in France. Work you do entirely from your own country can therefore fall within it once your French client uses it in France. Before the first invoice, write in the contract whether your fee is stated gross or net of any French withholding.
How the withholding is paid, and when a treaty changes it
The French payer files the form. The treaty between France and your country decides how much tax France can keep.
The French payer pays the tax it withheld by the 15th of the month after the calendar quarter in which it paid you, with form 2494-SD (BOFiP, § 100). The filing is your client's job. On your side, the withholding shows up as a payment lower than your invoice.
Provider resident in a country with a tax treaty
Article 182 B gives way to tax treaties. A provider resident in a country that has a treaty with France can claim the more favourable treatment that treaty provides (BOFiP, § 40 and § 95). The outcome depends on the treaty for your own country of residence, so read that text, not a general summary.
Provider established in a non-cooperative jurisdiction
The rate is 75% of the sums paid (CGI art. 182 B). Check whether the jurisdiction you invoice from is classed as non-cooperative by France before you sign. The list itself is outside this guide.
Your French client applies the treaty when it pays you, so it needs evidence of where you are resident for tax. The documents and forms it should hold are not set out in the sources we read. Agree them with your client and its adviser before the first payment, not after the tax has been withheld.
E-invoicing and e-reporting without a French establishment
France's reform reaches foreign sellers through reporting, not through the invoices they issue.
The French e-invoicing reform applies from 1 September 2026 to large and intermediate-sized companies and from 1 September 2027 to SMEs and micro-businesses (decree no. 2026-677 of 27 July 2026). A foreign company with no fixed establishment in France does not issue electronic invoices under the reform. It falls within e-reporting instead, through an approved platform (impots.gouv.fr).
Reverse-charged B2B services
When your service to a French business is taxed under the reverse charge, the French buyer is the party that reports the transaction (impots.gouv.fr).
B2C sales declared through the One-Stop Shop
Sales to consumers that you declare through the One-Stop Shop are excluded from the e-reporting of transactions (impots.gouv.fr). This covers a SaaS sold to individuals and declared there.
A separate strand of the reform covers payment data. Whether it reaches a service provider that declares its VAT through the non-Union One-Stop Shop is not settled in the official page we read. Treat it as open until the French tax administration answers it for your case.
The French digital services tax, and where VAT fits
One tax aimed at very large groups, and VAT rules set at EU level.
France charges a digital services tax of 3% on targeted advertising and digital intermediation services. It applies to groups above two thresholds: EUR 750 million of worldwide revenue and EUR 25 million in France. The version of the code dated 14 March 2026, which follows the 2026 finance law (no. 2026-103 of 19 February 2026), keeps the rate at 3%, and we found no change after March 2026 (CIBS art. L453-45, L453-65, L453-66 and L453-70). A consulting firm or SaaS company below those revenue levels is outside it.
VAT on cross-border services follows rules set at EU level, which our comparison of services and SaaS rules across Europe covers country by country. For consumer sales, a business not established in the EU can register for the non-Union One-Stop Shop in one Member State and declare there, in a quarterly return, the VAT due in all the others (European Commission). From 1 January 2027 the scheme covers all services supplied to consumers in the EU, with no condition on where the customer lives (Directive (EU) 2025/516).
Steps for a non-EU provider with French clients
In the order you meet them. Dates are those stated in the official sources.
Check article 182 B and your treaty
Decide whether the service is supplied or used in France, find the treaty between France and your country of residence, and state in the contract whether fees are gross or net of French withholding.
Give your client evidence of residence
Your French client applies the treaty when it pays you. Agree with it which documents it needs.
The French payer pays the withholding
Form 2494-SD. Ask your client for proof of payment of the tax withheld from your fees and keep it with your own tax records.
Non-Union One-Stop Shop return
Consumer sales declared there stay outside French transaction e-reporting.
The non-Union scheme covers all consumer services
The condition on where the customer lives falls away.
The e-invoicing reform reaches SMEs and micro-businesses
It has applied to large and intermediate-sized companies since 1 September 2026. Your smaller French clients join it on this date.
What the official sources do not settle
Several points remain open in the sources we read. The corporate income tax rate that applies to the article 182 B withholding in 2026 has not been re-read, because the BOFiP page dates from 2022. The detailed impots.gouv page on e-reporting for foreign companies could not be loaded, and we found no official answer on whether e-reporting of payment data covers a service provider that declares through the non-Union One-Stop Shop. The rows we verified speak of services of any kind and do not single out SaaS subscriptions or software licences. We did not read the individual tax treaties, so the relief open to you depends on the treaty with your country. Confirm each point with the French tax administration or a licensed adviser before you rely on it.
What Balt Partners coordinates
One contact in Riga for the French side of your client contracts. Where a filing or an opinion is needed in France, we bring in a licensed adviser in France.
French obligation map
For each French client: whether article 182 B applies, which treaty you rely on, your e-reporting position and the dates, in one calendar.
Treaty documents for your client
We help you assemble the residence evidence and contract wording your French client asks for. A licensed local adviser confirms the treaty treatment.
Filings and questions to the French tax office
When a filing or a written question to the French tax administration is needed, we bring in a licensed adviser in France and coordinate the file with you.
A Latvian company if you want an EU base
A Latvian SIA with its bank account and accounting set-up. It is still a non-resident for France, so article 182 B and the treaty question apply to its French invoices as well.
France is one market among several? Compare the withholding, digital tax and e-invoicing rules of other countries in our guide to selling services and SaaS in Europe. If an EU company fits your plans, see how non-residents form a company in the EU.
Questions from non-EU service and SaaS companies about France
In principle, yes. Under article 182 B of the French tax code, a payer carrying on an activity in France withholds tax on fees paid to a non-resident with no permanent professional installation in France, for services of any kind supplied or used in France. Consulting, development and marketing are covered. A tax treaty between France and your country takes precedence and can give you more favourable treatment.
The standard corporate income tax rate. The French tax authority's commentary, in its 2022 version, gives 25%. The rate rises to 75% when the provider is established in a non-cooperative State or territory. Confirm the rate that applies in 2026 before you price a contract.
The withholding gives way to tax treaties, and a provider resident in a treaty country can claim the more favourable treatment the treaty provides. The outcome depends on the treaty with your country. Your French client applies it when it pays you, so it needs evidence of your tax residence.
By the 15th of the month after the calendar quarter in which it paid you, using form 2494-SD. The filing and the payment are the French client's.
No. A foreign company with no fixed establishment in France does not issue electronic invoices under the reform. It falls within e-reporting through an approved platform. For reverse-charged business sales the French buyer reports, and consumer sales declared through the One-Stop Shop are excluded from transaction e-reporting.
Not below its thresholds. The tax is 3% on targeted advertising and digital intermediation services, and it applies only to groups above EUR 750 million of worldwide revenue and EUR 25 million in France.