BOFiP Publishes the Transitional Rules for the Move of VAT From the CGI to the CIBS on 1 January 2027 and Confirms That the E-Invoicing Reform Is Not Affected

KGT Country Update  |  France  |  9 October 2026

On 7 October 2026 the French tax administration published a new version of its ruling BOI-RES-TVA-000253 in BOFiP-Impôts, setting out the transitional rules for the entry into force of the ordinance that recodifies value added tax in the new Code des impositions sur les biens et services (CIBS). The legislative VAT provisions of the General Tax Code (CGI) move to Book II of the CIBS on 1 January 2027, at constant law. The ruling confirms that existing doctrine stays binding, that references to the CGI on invoices and in contracts remain valid until at least 30 June 2028, and that the e-invoicing reform is not affected.

Background

Ordinance No. 2025-1247 of 17 December 2025, published in the Journal officiel on 20 December 2025, recodifies VAT into the CIBS under the authorization in the 2024 Finance Law. It has since been amended by Ordinance No. 2026-671 of 27 July 2026, which carries the title portant divers ajustements du code des impositions sur les biens et services. The BOFiP ruling replaces the version that had been in force since 18 February 2026.

For a multinational group the practical concern is not the substance of French VAT, which does not change, but the references. Article numbers cited in ERP configuration, invoice templates, contracts, VAT return mappings and legal mentions are those of the CGI, and they will be renumbered.

The Legislative Change

This is guidance, not a new law. The ruling explains how the recodification ordinance applies from 1 January 2027 and states that it is a change at constant law: the substitution of references and terminology applies automatically to laws, regulations, administrative acts, invoices and existing contracts, and does not alter obligations. Until 31 December 2026 the VAT provisions remain in the CGI.

It is nonetheless binding in practice because it fixes what the administration will accept. It states that the administration’s doctrine, including BOFiP commentary and individual rulings that have not expired, remains enforceable against the administration from 1 January 2027, with references to repealed CGI articles read as references to the corresponding CIBS provisions.

Scope

The ruling covers the legislative provisions on VAT in Chapter 1 of Title II of the first part of Book I of the CGI, which move to Book II of the legislative part of the CIBS and become subject to the general rules in Book I. The regulatory provisions in CGI Annexes II, III and IV are not moved on 1 January 2027 and stay applicable until formally repealed. Taxes that are declared or paid in the same way as VAT, such as those reported in an annex to the VAT return, are unchanged in substance; their declaration rules move to the common declaration for taxes on goods and services (CIBS articles D. 161-25 to D. 161-34) and their payment rules to CIBS articles D. 171-1 to D. 171-6.

The ruling identifies a limited number of points that go beyond renumbering. Suspensive VAT regimes become exemption regimes under CIBS article L. 211-57, so that VAT is no longer deferred: an exemption with input VAT deduction applies and exit from the regime is treated like an import. The jurisdiction rule in article L. 199 of the Book of Tax Procedures is amended so that administrative courts are the default tax courts, although the ruling expects no practical change on 1 January 2027. The designation rules for the VAT payer on imports are unchanged, with the taxable person who opts in by providing a VAT number liable under CIBS article L. 215-14.

Timeline

• 17 December 2025 — Ordinance No. 2025-1247 recodifies VAT in the CIBS; published 20 December 2025.

• 18 February 2026 — earlier version of ruling BOI-RES-TVA-000253 enters BOFiP.

• 27 July 2026 — Ordinance No. 2026-671 makes various adjustments to the CIBS.

• 7 October 2026 — current version of the ruling published.

• 1 January 2027 — VAT provisions move from the CGI to the CIBS.

• 30 June 2028 — until at least this date, acts, contracts and invoices that still cite the CGI remain valid, and legal mentions on invoices may still refer to the CGI.

• 1 July 2028 and 1 July 2030 — staggered entry into force of the articles of the ordinance that transpose Directive (EU) 2025/516 and Directive (EU) 2025/1539.

Businesses Affected

All VAT-registered businesses in France and all groups that issue or receive French invoices. The effort concentrates in tax and finance teams that maintain legal references in SAP and other systems: invoice legal mentions, tax code descriptions, VAT return and e-reporting mappings, contract templates and internal tax manuals.

Required Actions

• Inventory every place where a CGI article number appears in ERP configuration, output forms, tax code text, templates and contracts, and decide which will be changed on 1 January 2027 and which will be left until the end of the tolerance period.

• Use the Légifrance concordance tables between the CGI and the CIBS, and the glossary in BOI-ANNX-000514, as the mapping source.

• Confirm with the e-invoicing platform and ERP vendors whether the legal mention fields in the structured invoice are free text or code-controlled, because the ruling says that invoicing format and data transmission rules stay in the CGI from 1 January 2027 and move later, unchanged.

• Review any use of suspensive VAT regimes, because the ruling changes how they are characterized.

• Do not change the e-invoicing or e-reporting calendar because of the recodification; the ruling states that its timetable, content and implementation are not affected.

Practical Implications

The tolerance until 30 June 2028 removes the risk of invoices being invalid because they cite the old article, and makes a phased clean-up possible. It also means that for 18 months two sets of references will be correct at the same time, so mapping tables should hold both. The ruling confirms the continuity of the existing invoicing rules but, as read by KGT, does not say how the reference should be shown in structured e-invoices, so any decision to switch should be made together with the platform provider.

The ruling also states that the articles of the ordinance that transpose Directive (EU) 2025/516 enter into force on 1 July 2028. That is the first of the staggered dates after the move of 1 January 2027 and should be on the program calendar alongside it.

Expected Next Steps

BOFiP will update its VAT commentary gradually to refer to the CIBS, and the regulatory provisions in the CGI annexes will be transposed to the regulatory part of the CIBS later. The parts of the two directives that fall under regulatory law will also be transposed later.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. We implement and run SAP Document and Reporting Compliance (SAP DRC) and deliver SAP-integrated e-invoicing add-ons where DRC does not yet cover a requirement or where a transformation programme makes a DRC rollout impractical in the available window. Our work is done inside the SAP landscape rather than around it, so VAT determination, document creation, transmission, status handling and reconciliation stay in one place.

For France KGT can inventory the legal references in your SAP configuration, invoice output and e-reporting mappings, and implement the change so that it runs in step with the e-invoicing and e-reporting program that started on 1 September 2026.

This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.