Fiscal subject related
General information
From 1 September 2026, VAT rules currently set out in the General Tax Code (CGI) will be transferred to a new legal framework: the Code of Taxes on Goods and Services (CIBS).
This “non-negotiable” reform modernises and simplifies the structure of VAT law without changing its content. Its goal is to make VAT rules more transparent, consistent, and accessible for businesses and practitioners. It incorporates recent CJEU case law but does not alter core VAT principles, taxation rules, or deduction mechanisms.
What Changes and What Remains the Same
- Unchanged: VAT principles, taxation rules, and deduction mechanisms.
- Changed: Structure, organisation, and article numbering of the VAT legislation.
Transitional Provisions
To ensure a smooth transition:
- Transactions before 1 September 2026 remain governed by the CGI.
- Transactions from 1 September 2026 fall under the CIBS, leading to a temporary coexistence of both frameworks (especially in audits and disputes).
- Existing administrative doctrine (BOFiP) and rulings based on the CGI remain useful references, but their enforceability under CIBS will be clarified by the tax authorities.
- Rulings obtained under the CGI stay valid for the situations they cover, subject to alignment with the new CIBS framework.
- The administration will publish CGI/CIBS correspondence tables to help identify equivalences between old and new articles.
- Current regulatory texts remain applicable and will be gradually integrated into the CIBS.
Timetable
- 18 February – 15 April 2026: Public consultation on transitional provisions.
- 1 September 2026: Entry into force of the CIBS for VAT.
- 2027: Finalization and ratification.
Impact on Businesses
The reform requires operational adjustments, including:
- Updating ERP and tax software
- Reviewing internal VAT procedures
- Adapting contracts and tax clauses
- Training teams
It also brings opportunities: clearer VAT rules, simplified access to tax information, and strengthened legal certainty.
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