Reverse charge on import VAT becomes mandatory in France from January 2022

BREXIT TURMOILS REVIVED CHANGES OF VAT RULES FROM 1 JANUARY 2022 v. 2021.04 | December 2021

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HAUTS-DE-FRANCE VITAL LINK IN UK-EU TRADE → Nearby • UK’s closest neighbour • Proximity to many European markets → Efficient • Dense and multi-modal transport and logistics networks • Customs and tax environment adapted to postBrexit world

→ Resilient • Diversity of sectors • Diversity of skills and human capital

HAUTS-DE-FRANCE EXCELLENCE DANS LA LOGISTIQUE → Roads

• Densest highway network in France • 12 highways, linking capitals → Railways

• 10% of French railway network • Booming rail freight, European connections → Ports

• • • •

Strong Calais-Dover connection Boulogne, fish market leader Dunkirk, global connections Eurotunnel

→ Waterways

• 1.035km of navigable waterways • Canal Seine Nord Europe project

Introduction Some facts about RM Boulanger

1981 Founded

315.000€ Share capital

ADDRESS Rue du Vertuquet 17A, Neuville-en-Ferrain, France

30

900

2.8bn

Employees

Customers established in 45 countries

Transactions reported to national Tax Authorities

PHONE

E-MAIL

WEBSITE

+33 03 20 25 70 70

contact@rmboulanger.com

www.rmboulanger.com

What do we do?

•

VAT registration & compliance in all the EU member states,

•

Overall VAT consultancy,

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Brexit dedicated service (both for EU and UK companies),

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Acting as the ‘economic operator’ in the EU for EC-marked products.

IN A NUTSHELL: assisting companies to trade within the EU as if Brexit NEVER happened!

RMB

Main bottlenecks today arising from Brexit

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Complexity of Customs processes

Veterinary and Sanitary inspections and certification

Huge pressure on supply chain and delivery times

Administrative burden

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Not enough awareness regarding fiscal liabilities. VAT is an issue that needs to be managed carefully.

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The reality from a fiscal point of view since 1 January 2021

B2B transactions are no longer EUharmonized but as exports and imports between EU and the UK

Customs duties to be paid on imports in the EU (unless products qualify as of UK origin)

Products imported in the EU attract import VAT

Most of EU clients require to be supplied on a DDP basis.

RMB can help you map your flows and determine how to ship DDP to the EU as if Brexit did not happen!

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BEWARE OF THE NEW VAT RULES

Importers / Sellers in France (B to B & B to C)

French VAT number needed

IMPORT VAT DEFERMENT / « AUTOLIQUIDATION» WILL BECOME MANDATORY AS PER 1 JANUARY 2022.

A French VAT registration is therefore required for all companies importing goods into France from 1 January 2022!

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BEWARE OF THE NEW VAT RULES FROM 1 JANUARY 2022 As a result:

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The VAT on import is no longer payable to your French customs broker,

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You cannot sell DDP to French clients if your company does not have a valid French VAT number,

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VAT refund reclaims through the 13th directive are no longer possible for import VAT.

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BEWARE OF THE NEW VAT RULES FROM 1 JANUARY 2022

Downside of these measures: VAT registration in France can take up to 3 months.

A BLESSING IN DISGUISE: •

No IMPORT VAT to be prefinanced ever again,

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No longer be stuck in time-consuming procedures to get the VAT on import refunded,

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One VAT number that can be used to deliver DDP to both French and other EU clients,

➔ It will be worth waiting 2 or 3 months to be VAT registered!

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BEWARE OF THE NEW VAT RULES FROM 1 JANUARY 2022

What can RMB do for you so that your imports in the EU are not blocked while your VAT number is being processed?

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Share are global VAT number and use REGIME 4200,

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This solution is only applicable to DDP sales in the EU but NOT in France.

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HOW TO KEEP ON SELLING DDP AFTER JANUARY 1st 2022?

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Obtain an EU EORI NUMBER. This is a customs ID number, enabling you to perform imports in any EU country on your own name. Easy to get, we can take care of it in usually less than 24 hours,

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Appoint RMB as your Tax Agent and register for VAT ➔ Enabling you to use postponed VAT accounting,

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Appoint a Customs Broker in the UK to fulfill the export formalities,

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Appoint a Customs Broker in France to clear your goods and fulfill the import formalities on your name.

France remains an attractive import country: •

Mutual tax reciprocity between France and the UK,

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No requirement to set up a bank guarantee with the French tax authorities,

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Lower VAT compliance costs.

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CASES

CASE 1: Your company sells to French businesses only OUR SOLUTION Register for VAT in France and benefit from a full import VAT deferment on all imports.

BENEFITS

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Import VAT is exempted on all goods,

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Your company has its own French VAT number that can be potentially used to sell to other EU member states on a later stage (business expansion, etc.).

PROCESS

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Appoint a customs broker in France,

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Appoint RMB as your tax agent in France,

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Mention your own French VAT numbers on your invoices,

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RMB will report these transactions to the French Tax Authorities for VAT purposes.

Note that having a French VAT number will allow you to sell goods in other EU member states as well.

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CASES

CASE 2: Your company sells BOTH to French and EU-based clients OUR SOLUTION Register for VAT in France with RMB AND use limited tax representation (regime 4200) as a temporary solution for goods being sold to EU-based clients, until receiving your own number.

Once registered for VAT in France, benefit from a full import VAT deferment on all imports, regardless of the destination of goods.

BENEFITS

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Import VAT is exempted on all goods, whether they are shipped to EU customers or sold to French clients,

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Your company has its own French VAT number.

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PROCESS

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Appoint a customs broker in France,

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Appoint RMB as your tax agent in France,

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Mention your own French VAT numbers on your invoices,

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RMB will report these transactions to the French Tax Authorities for VAT and INTRASTAT purposes.

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CASES

CASE 3: Your company sells to EU businesses (except French) using France as the sole point of entry in the EU THE LIMITED TAX REPRESENTATION (REGIME 4200)

PROCESS

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Can be used immediately,

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Appoint a customs broker in France,

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No VAT to pay upfront at time of import in France,

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Goods are customs cleared in France in your name,

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No VAT registration required in France,

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Goods are immediately transported to your EU customers,

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Your goods are shipped from the UK to all EU countries on a DDP basis,

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Your company mentions RMB's Global VAT number on invoices,

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Your clients are not involved in the customs process in their countries.

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RMB will report these transactions to the French Tax Authorities for VAT and INTRASTAT purposes.

OR REGISTER FOR VAT IN FRANCE FOR MORE TAX STABILITY 16

THIS METHOD IS NOT APPLICABLE TO SALES IN FRANCE CONQUER EUROPE WE’LL HANDLE THE PAPERWORK

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Q&A SESSION

This presentation was produced by RM BOULANGER in consideration of the texts and data available on the date of its presentation. The information it contains as well as that communicated orally cannot be considered as advice or consultation. RM BOULANGER is not responsible for the accuracy or completeness of this content and is not responsible for any errors or omissions.

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We remain at your disposal for any questions or additional information ...

This presentation was produced by RM BOULANGER in consideration of the texts and data available on the date of its presentation. The information it contains as well as that communicated orally cannot be considered as advice or consultation. RM BOULANGER is not responsible for the accuracy or completeness of this content and is not responsible for any errors or omissions.

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MICHAEL BOULANGER

ARTUR SARKISIAN

CEO

OPERATIONAL MANAGER

Tel. +33 3 20 25 70 70 mboulanger@rmboulanger.com www.rmboulanger.com

Tel. +33 3 20 25 70 84 a.sarkisian@rmboulanger.com www.rmboulanger.com