VAT — Filing regimes

French VAT return:
how to complete the CA3

Article 287 of the French Tax Code sets out three VAT filing regimes: the small-business exemption (no return required; French Tax Code art. 293 B, year N-1 thresholds: €85,000 for total turnover / €37,500 for supplies of services other than accommodation); the simplified regime (RSI) with half-yearly instalments and an annual CA12 return (French Tax Code art. 302 septies A, 2026-2028 thresholds: €945,000 for sales/accommodation / €286,000 for other services, annual VAT ≤ €15,000); and the standard actual regime (RN) with a monthly return (or quarterly where annual VAT is below €4,000) filed on form CA3. The CA3 return is the reference form for significant activities: its proper preparation determines the right to deduct and the legal certainty of taxpayers. This page summarises the essential rules and the most frequent pitfalls.

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— In brief
Applicable text
French Tax Code art. 287: filing regimes
Standard actual regime
Monthly CA3 (or quarterly where annual VAT is below €4,000)
Simplified regime
Half-yearly instalments + annual CA12
Small-business exemption
French Tax Code art. 293 B: no return below the thresholds
Electronic filing
Mandatory (EDI or EFI via impots.gouv.fr)
— 01

A seemingly routine return with substantial stakes

For companies under the standard actual regime, the CA3 is the monthly return (quarterly in certain cases) that records the operations carried out and the calculation of output and input VAT. Its quality directly determines the right to deduct, the regularity of the company's VAT position and its defence in the event of a tax audit.

Three recurring issues: (1) consistency between the CA3 and the accounts (each CA3 line must be supported by a precise accounting entry); (2) the correct treatment of specific operations (reverse charge, adjustments, residual self-supplies, deduction ratio); (3) compliance with filing and payment deadlines (electronic filing is mandatory; lateness is penalised under articles 1727 and 1728 of the French Tax Code).

The firm secures the VAT returns of companies with significant exposure (mixed activities, international operations, complex real estate) and defends taxpayers against reassessments and adjustments.

— 03

Two case studies handled by the firm

Anonymised. Amounts are rounded. Documents and procedural steps can be substantiated on request, subject to professional secrecy.

Company X: construction reverse charge, reassessment reduced from €240K to zero

A finishing-works company, turnover of €8M, audited over 3 financial years. The tax authorities identified a failure to apply the reverse charge on cascading subcontracts (French Tax Code art. 283, 2 nonies) and notified a reassessment of €240K plus interest and a 40% surcharge. Our strategy: demonstrating (1) the economic neutrality of the reverse charge where the subcontractors have a full right to deduct, (2) good faith supported by the BOFiP doctrine in force at the time of the operations, (3) the spontaneous regularisation initiated before the reassessment proposal. Outcome: the reassessment was abandoned in full after exchanges with the auditor and a hierarchical appeal.

Property company Y: mixed deduction ratio, coefficients secured over 5 years

A family property company holding buildings let with and without VAT, turnover of €12M. An internal review revealed deduction coefficients calculated inconsistently between 2020 and 2025. Our work: (1) reconstitution of the liability, taxation and admission coefficients by business sector, (2) an organised regularisation on the following return with an explanatory letter, (3) a provision of €90K. The tax authorities accepted the regularisation with late-payment interest only (art. 1727), without any surcharge. Estimated net saving: approximately €150K compared with a litigation scenario.

— VAT portal

6 operational sub-pages

01

CA3: a section-by-section guide

The logic of form 3310-CA3, sections A to F, focus on box E2 (other non-taxable operations), frequent pitfalls.

  • Section A (identification) to F (special cases)
  • Box E2: discrepancies with the tax package
  • Coordination of the CA3 with the DEB and DES
  • Pre-audit review
See the CA3 guide
02

CA3 or CA12: which regime?

Comparison of the standard actual and simplified regimes for 2026-2028. Thresholds set by the Order of 27 January 2026 (€945K / €286K + VAT ≤ €15K).

  • French Tax Code art. 287 (CA3) vs 302 septies A (CA12)
  • Mini-actual regime: election for the CA3 below the RSI threshold
  • Automatic exit from the RSI
  • Cash-flow comparison
See CA3 or CA12
03

Construction reverse charge

Subcontracted construction works (French Tax Code art. 283, 2 nonies + Law 75-1334). Subcontracting chains, mandatory invoice mention.

  • Scope: construction works on buildings
  • Multi-tier subcontracting chains
  • Mandatory "Autoliquidation" mention
  • Penalties under French Tax Code art. 1788 A (5%)
See the construction reverse charge
04

Intra-Community reverse charge

EU acquisitions of goods (French Tax Code art. 256 bis) + B2B services (French Tax Code art. 283, 1). Coordination of the CA3 with the DEB and DES + VIES database.

  • Intra-Community acquisitions of goods
  • B2B services (Directive 2008/8/EC)
  • Triangular operations (art. 258 D-I-4°)
  • 2020 quick fixes (chain transactions)
See the intra-Community reverse charge
05

Deduction ratio

Liability, taxation, admission and deduction coefficients (French Tax Code ann. II art. 205-210). Adjustments by twentieths.

  • Coefficient = Liability × Taxation × Admission
  • Mixed activities (property companies, banks, holdings)
  • Annual adjustments + twentieths for buildings
  • Coordination with the single taxable person
See the deduction ratio
06

Separate business sectors

VAT sectorisation (French Tax Code ann. II art. 209 + 213). An optimisation lever for mixed property companies, animating holdings and training organisations.

  • Direct allocation of input VAT by sector
  • Conditions: separate accounts + notification to the tax office
  • Mandatory sectorisation (art. 213) or by election (art. 209)
  • Coordination with the single taxable person (French Tax Code art. 256 C)
See separate sectors
— 02

5 key points of the CA3 return

1. Output VAT: breakdown by rate

The CA3 distinguishes operations according to the applicable rate: 20% (standard), 10% (intermediate: accommodation, on-site catering), 5.5% (reduced: food products, books, etc.), 2.1% (super-reduced: reimbursable medicines). The taxable base is broken down into separate lines; an incorrect characterisation distorts the calculation.

2. Input VAT: deduction coefficients

For taxpayers with mixed activities (taxed and exempt), the deduction is calculated using coefficients (liability, taxation, admission). Calculating the applicable ratio can be complex; see our analysis of the payroll tax in the case of mixed activities.

3. Reverse charge: cross-border operations and works

Several operations fall under the reverse charge: intra-Community purchases, cross-border B2B supplies of services (French Tax Code art. 283, 2), construction works between taxable persons (French Tax Code art. 283, 2 nonies). The CA3 provides separate lines for these operations, with the VAT reported simultaneously as output and input VAT.

4. VAT credit and refund

Where input VAT exceeds output VAT, the balance is a VAT credit. It can be carried forward to the next return or be the subject of a refund claim (dedicated form; see our analysis of the audit of refund claims). Refund timelines vary depending on the regime.

5. Penalties for errors and omissions

An error or omission can be corrected spontaneously on a subsequent CA3 (corrective entry). Where the correction follows a tax audit, late-payment interest applies (French Tax Code art. 1727: 0.20% per month) plus a surcharge (French Tax Code art. 1728 or 1729 depending on the grounds). An isolated, well-documented error may benefit from the tax authorities' tolerance; a systematic failure leads to heavier penalties.

— Interactive table

Which VAT regime for your activity?

Select a regime to compare thresholds, filing frequency, forms and penalties. Data for 2025/2026, updated for the suspension of the small-business exemption reform (DGFiP instruction of 30 April 2025). This is an educational tool: the operational characterisation should be confirmed with the firm.

Sources: French Tax Code art. 287 (standard actual regime, CA3), 302 septies A (RSI, CA12), 293 B (small-business exemption), 1727/1728/1729 (penalties). BOFiP-TVA-DECLA. DGFiP forms 3310-CA3 and 3517-S-SD (CA12, 2026 edition, Order of 27 January 2026 published in JORF No. 0023 of 28 January 2026), 3514, 3519. RSI thresholds set for the 2026-2028 period by the same order.

— 04

Our approach at the firm

The firm assists companies and groups with significant VAT exposure in securing their CA3 returns: review of deduction coefficients, treatment of specific operations (reverse charge, deduction ratio, separate sectors), coordination with the payroll tax, and defence in the event of a tax audit.

For exceptional operations (real-estate disposals, transfers of a going concern, restructurings), we coordinate the drafting of the deeds and the reporting treatment to ensure the consistency of the positions taken.

On VAT regularisations, the spontaneous window is worth far more than anything you will obtain in litigation. Documenting your good faith before the audit divides the cost of an error by ten.
— François Ouairy, partner, VAT & real-estate taxation practice
— Frequently asked questions

What is the difference between the standard actual regime and the simplified regime?

The standard actual regime requires a monthly return (CA3) unless annual VAT is below €4,000, in which case a quarterly return applies. The simplified regime (RSI) consists of two half-yearly instalments (July and December) calculated on the VAT of the previous financial year, plus an annual CA12 reconciliation return. The RSI is available to companies below certain turnover thresholds (French Tax Code art. 302 septies A).

How is a late VAT return or late payment penalised?

Three cumulative penalties: (1) late-payment interest under article 1727 of the French Tax Code (0.20% per month, i.e. 2.40% per year) on the VAT due; (2) a surcharge of 10% for late filing (French Tax Code art. 1728, 1, a), increased to 40% where a formal notice has remained unanswered, or to 80% where an undisclosed activity is discovered; (3) where applicable, interest in the event of litigation. A spontaneous regularisation before any audit considerably limits the penalties.

What should be done if an error is found in a filed CA3?

The error can be corrected through a corrective return via the electronic filing system (entry on the following month's CA3 or a dedicated form). For errors involving significant amounts or several periods, an organised regularisation with an explanatory letter to the tax authorities can limit the penalties to late-payment interest only. The rationale: demonstrating good faith and the absence of deliberate default.

How does the reverse charge work on the CA3?

For a reverse-charge operation, the taxpayer reports the amount simultaneously as output VAT (dedicated line) and as input VAT (according to the applicable coefficient). In practice, the operation is neutral on the CA3 balance unless the deduction coefficient is below 1, in which case the non-deductible output VAT remains due. Typical cases: intra-Community purchases, cross-border B2B services, construction works between taxable persons (French Tax Code art. 283, 2 nonies).

How can a VAT credit refund be requested?

The refund claim is filed electronically at the same time as the CA3 (form 3519). Timelines and procedures vary depending on the regime; for claims of €760 or more, the refund is in principle processed quickly. The tax authorities have a power of on-site audit (Tax Procedure Code art. L.198 A; see our dedicated analysis).

Does the small-business VAT exemption remove all filing obligations?

Yes, subject to conditions. Article 293 B of the French Tax Code (as amended by the 2025 Finance Act) allows taxpayers whose turnover remains below certain thresholds to benefit from the small-business exemption: no output VAT, no deduction, no CA3. Thresholds in force for 2026: previous calendar year €85,000 (total turnover) / €37,500 (supplies of services other than on-site consumption and accommodation); current year €93,500 / €41,250. A special regime applies to lawyers, authors of works of the mind and performers: €50,000 / €35,000 (year N-1) and €55,000 / €38,500 (current year). The €25,000 reform initially provided for by article 32 of the 2025 Finance Act was suspended and then definitively repealed by the Law of 3 November 2025.

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François Ouairy, avocat associé

Written by

Me François Ouairy, avocat associé en charge du bureau de Paris, expert en fiscalité immobilière, fiducie et fiscalité financière.

© BENSAID Avocats — The information on this site does not constitute legal advice and cannot replace a personalised tax analysis.