Fiscal Partner
Leading firm for French VAT fiscal representation, compliance and support of companies not established in France. Dedicated contact, multilingual follow-up.
Visit the website8th and 13th directives, two refund regimes
Directive 2008/9/EC, known as the 8th directive, governs the refund of VAT paid in another Member State of the European Union by a company established in the EU. The claim is filed electronically on the portal of the State of residence (in France, via impots.gouv.fr, professional area, section "VAT, request for refund of VAT borne in another Member State"), which forwards the file to the tax authority of the country of expense. The maximum deadline set by the directive is four months from receipt, extended to eight months in the event of a request for additional information.
Directive 86/560/EEC, known as the 13th directive, governs refunds to companies established outside the European Union. Each Member State sets its own terms, subject to the principle of reciprocity: France only accepts claims from companies established in countries that themselves refund VAT to French companies. The list of countries benefiting from French reciprocity appears in BOFIP, section BOI-TVA-DED-50-20-30-30. Conversely, French recovery in certain third States can be slow, costly, or simply impossible where reciprocity is not recognised.
Refunds always transit through the tax authority of the country of expense. The minimum claim thresholds are €400 for a quarterly claim and €50 for an annual claim under the 8th directive, with equivalents set by each Member State for the 13th directive. Below these thresholds, the claim is inadmissible and the VAT is definitively lost.
Eligible expenses, countries and schedule of deadlines
Eligible expenses are business expenses incurred in the country of refund, invoiced with VAT by a local taxable person, not already refunded, and compliant with local rules on the right to deduct. Certain expenses are specifically excluded depending on the Member State: alcohol, tobacco and luxury purchases in Germany, hospitality and restaurants in Italy for directors, entertainment expenses in Spain, private vehicle tax in Portugal. Each firm maintains an eligibility matrix by expense type and by country.
| Expense category | Intra-EU eligibility | Frequent exclusions |
|---|---|---|
| Hotels and restaurants | Broad, country-dependent | DE, IT (directors), HR |
| Trade fairs, conferences | Very broad | Occasional |
| Fuel and tolls | Partial | Petrol for passenger cars in many countries |
| Vehicle rental | Partial | Passenger vehicles, local exclusions |
| Freight transport | Broad | Few exclusions |
| Training and recruitment | Very broad | Few exclusions |
Deadlines are strict. Under the 8th directive, the annual claim must be filed no later than 30 September of the year following that of the expense. Under the 13th directive, 30 June of the following year is the cut-off date for France, with other countries applying different dates (30 June in Germany, 30 September in Italy). Missing a deadline means the definitive loss of the right. The best firms put in place a multi-country schedule that groups claims by deadline, avoiding the risk of prescription.
Services of a foreign VAT recovery firm
The service combines documentary collection, tax engineering and multi-country administrative follow-up. Eight concrete services structure the offering.
- Initial mapping of countries of expense, volumes by category, simulation of annual recovery potential, prioritisation of countries with the best cost/benefit ratio.
- Collection of original or digital invoices (certified PDF, e-invoicing), form checks (name, address, supplier and customer VAT numbers, description of the service, amounts excluding taxes and VAT, applicable rate).
- Eligibility sorting by country and by category, reconciliation with the accounting records, exclusion of non-deductible expenses under local rules, reclassification of poorly qualified invoices.
- Preparation of the electronic file in the format required by each national portal, submission of the claim in the State of identification (8th directive) or directly with the foreign authority (13th directive).
- Handling of requests for additional documents from the foreign authority, free translation of invoices, eligibility notes based on the directive and local doctrine, follow-up of exchanges within the allotted time.
- Disputes: memorandum against a partial refusal, hierarchical appeal, referral to local administrative courts, use of article 170 of the VAT directive for uniform application rules.
- Cash-in and reconciliation: control of the transfer into the company's account, reconciliation with the initial claim, handling of any discrepancies, issuance of a fee invoice on a percentage or fixed-fee basis.
- Continuous improvement: ERP configuration recommendations (SAP, Oracle, Sage, Cegid) to automatically isolate foreign VAT from entry onwards, training of travel and procurement teams, annual update of the eligibility matrix.
Deliverables include a dashboard by country and by fiscal year, filing acknowledgements, acceptance or refusal decisions, a variance report, and the annual closing note. The added value is measured both on the amount actually recovered, on the reduced risk of prescription, and on the capability-building of internal teams.
Average refund timelines by country
The chart below shows the average timelines observed between the submission of a complete claim and the effective transfer, for the main countries of expense. These values, compiled from field feedback of specialised firms, are used to calibrate forecast cash and to prioritise countries for a first recovery project.
Criteria for choosing your firm
Four criteria structure the choice. First, real geographical coverage. A French firm that subcontracts Germany, Italy and Spain to local correspondents has weak control over deadlines and specificities. The best players operate directly in the 25 to 30 high-potential countries (EU, United Kingdom, Switzerland, Norway, Canada, United Arab Emirates).
Second, automation of collection. An ingestion platform that connects to SAP Concur, Expensya, Workday or Cegid Note de frais turns a time-consuming service into an industrial flow. The best-equipped firms process tens of thousands of invoices per quarter without error.
Third, legal strength on partial refusals. A firm that never challenges a refusal effectively accepts a loss of yield. High-performing firms file appeals on 10 to 20 per cent of refused files, with a 40 to 60 per cent success rate on properly argued disputes.
Fourth, transparency of billing. The dominant model is a percentage of the amount recovered (10 to 20 per cent under the 8th directive, 15 to 25 per cent under the 13th directive). Requiring the breakdown of fixed/variable costs, appeal fees, translation fees and early-termination terms protects against surprise invoices.
Comparative analysis and field feedback
The market is made up of three families. International pure-players (VAT IT, Taxback International, Meridian, Cash Back) operate across 40 countries and more, bill on a percentage basis, and heavily tool their operations. Integrated tax firms (Fidal, Taj, EY, KPMG) manage foreign VAT recovery as one brick of their global tax offering, with higher fees but fine articulation with French VAT compliance. Accredited Tax Representatives (Représentants Fiscaux Accrédités — Fiscal Partner, Fiscal Connexion, Experts TVA, TEVEA International, Accréditéco) offer an integrated proposition that is particularly useful for clients already supported on VAT registration or fiscal representation.
Field feedback highlights three success factors: a strong internal sponsor (CFO or head of procurement), an awareness campaign among travel teams to enforce VAT capture from the moment of booking, and clear arbitrage between high-yield countries (Germany, Netherlands, Switzerland, Luxembourg) and low-yield countries (Portugal, Greece, Hungary) where processing fees can exceed the VAT recovered. Conversely, typical mistakes include underestimating the stock of electronic invoices to re-qualify, the lack of internal policy on invoices issued in the name of the employee rather than the company, and the submission of incomplete claims generating chain rejections.
A mid-sized group that industrialises its recovery across 15 countries generally reports a net gain of 0.15 to 0.40 per cent of its revenue, and a 30 to 50 per cent reduction in the average cash-in timeline thanks to platformisation.