From Jan. 1, 2026, France will stop allowing non-EU companies to use Regime 42 through a limited tax representative. Until now, foreign companies could import their goods into France and transit directly to another EU member state without registering for VAT in France. This was done through a temporary representative who used the French VAT number and assumed all VAT obligations.

Additional obligations and higher costs for non-EU companies

This practice is now coming to an end. Companies from outside the European Union that import via France will now have to register for VAT in France and file their own returns. This entails additional administrative obligations and can lead to delays and higher costs because tax representation is a cash flow benefit.

Thus, although Regime 42 will remain as a customs procedure, the possibility of applying it through limited tax representation will disappear. For many non-EU companies, this means a change in their logistical and tax processes due to the immediate VAT payment upon clearance of the goods and having to reclaim later which can take months.

Similar to the Dutch Article 23 regulation

The system used by France is similar to the Article 23 regulation we have in the Netherlands. This arrangement allows the VAT on imports to be shifted to the VAT return, which means no VAT has to be paid in advance.

This has important benefits for your business:

• You reduce administrative burden
• Preserves your liquidity by not having to make VAT pre-payments
• You can handle your imports faster and more efficiently.

The Netherlands as an attractive alternative

In the Netherlands, this arrangement remains in place. This makes the Netherlands an attractive alternative for imports within the European Union. For non-EU companies, this offers opportunities to smooth their goods flows, reduce costs and avoid complex VAT obligations. By using limited fiscal representation, this process can be completely outsourced, allowing you to focus on your core business.

How Neele-Vat can help

Want to know how this works in practice and what opportunities are available for your business?

At Neele-Vat, we offer companies from outside the EU the opportunity to take advantage of this under limited fiscal representation. We take care of the complete VAT handling, so that your imports can take place efficiently and without VAT pre-financing.

Please feel free to contact us to discuss your options. We will be happy to think with you about a suitable solution.