HR consultant: VAT on your services, from deposits to subcontracting

Quick answer. An HR consultant bills services of differing natures: social audit, organisational consulting, outsourced payroll and recruitment fall under VAT at 20 %, while continuing professional training can be exempt with an attestation from the DREETS (French Tax Code art. 261, 4-4°). The difficulty is allocating these regimes across one engagement, booking deposits at the right time and handling subcontracting and rebilled expenses correctly.

The work of an HR development consultant is rarely uniform. For a single client you might audit the payroll function in the first quarter, run a management training course in the second, then lead a recruitment in the third. These activities do not all follow the same VAT regime. Mistaking a taxable consulting service for an exempt training action, or billing a deposit without declaring the matching VAT, exposes you to a reassessment often discovered two years later during an audit. This article reviews, service by service, the tax mechanics of the HR consultant in 2026.

The basic rule is simple: a service between professionals is subject to VAT at the standard rate of 20 %. This covers the vast majority of what an HR consultant bills.

Social and payroll audits, organisational and HR consulting, management coaching, recruitment (search, selection, direct approach) and professional coaching all fall under VAT at 20 %. No exemption is specific to these activities: they are taxable like any intellectual service.

The only real exception is continuing professional training. When delivered by an organisation holding an attestation, it is exempt from VAT. That dividing line, taxable consulting on one side, exempt training on the other, shapes the entire billing of an HR consultant.

The VAT exemption for training actions is set by article 261, 4-4° of the French Tax Code. It covers continuing professional training as defined by article L6313-1 of the Labour Code. Three points deserve attention, as they are systematically underestimated.

First, the exemption is neither automatic nor a right. It requires an attestation issued by the DREETS (the regional directorate for the economy, employment, labour and solidarity), requested through a dedicated form. The DREETS has three months to reply, with silence amounting to acceptance. Until you hold that attestation, your training actions remain subject to VAT at 20 %, even if they materially fall within continuing training.

Second, the attestation presupposes a prerequisite: holding an activity declaration number with the DREETS and keeping an up-to-date educational and financial report. Without these training-provider formalities, the exemption is out of reach.

Finally, once the attestation is obtained, your training invoices must carry the wording "VAT exempt, art. 261-4-4° of the CGI". This wording justifies the absence of VAT and secures the service in case of an audit. We detail this mechanism from the freelance trainer's angle in our article on the status and VAT of the professional coach.

The classic trap is to present consulting or coaching as training to benefit from the exemption. Without an attestation and without a genuine link to continuing professional training, the exemption is denied and the VAT reassessed, with late-payment interest.

On an engagement spanning several months, the HR consultant often asks for a deposit at order, then bills the balance on delivery. The question is then: when is VAT due?

For services, VAT is in principle chargeable on collection of the price or deposits (CGI art. 269, 2-c). In practice, as soon as you collect a deposit, the matching VAT becomes chargeable and must appear on the return for the relevant month or quarter, even if the service is not finished. The triggering event (performance) and chargeability (the moment the State can claim the tax) are therefore separated.

You may opt for chargeability on debits, that is, when the invoice is issued. This option, set by article 269, 2-c, can never push chargeability beyond collection: if you collect a deposit before billing, the VAT is still due on collection. The debits option mainly serves to align your output VAT with your accrual accounting. For the full filing calendar, see our guide on the VAT return.

In practice, tracking chargeability is the point on which we most often correct consultants: a deposit collected at quarter-end triggers immediate output VAT that must not be forgotten on the return.

Many HR consultants act as subcontractors for a training organisation, or subcontract part of their own sessions to freelance trainers. The VAT question then becomes more complex.

The principle is that the exemption follows the nature of the service but remains conditional on holding an attestation. A subcontracting trainer can bill without VAT only if they hold their own attestation. Otherwise they bill the contracting organisation with VAT at 20 %, even if the final training, rebilled to the client by the attested organisation, is itself exempt. Administrative case law has evolved on this point, and we recommend caution: have your situation validated before billing without VAT as a subcontractor, rather than regularising afterwards.

Conversely, for your subcontracted consulting, audit or recruitment work, no exemption or reverse charge applies: the subcontracting reverse-charge mechanism is reserved for construction and does not concern intellectual HR services. Subcontracting is therefore billed with VAT at 20 %, like an ordinary service.

The HR consultant travels: trains, hotels, meals. Two treatments coexist, with different consequences.

The general case is that of accessory expenses. When you incur costs in your own name to carry out the engagement, then rebill them to the client, they form part of the price of your service. They therefore follow the regime and rate of the main service: 20 % if the service is taxable. A train ticket of 90 € rebilled within a consulting engagement thus bears VAT at 20 %, regardless of the ticket's original rate.

The special case is that of disbursements. If you incur an expense in the name and on behalf of the client, under a mandate, keeping the supporting documents in the client's name and recording the sum in a third-party account, the reimbursement is excluded from your VAT base (CGI art. 267, II-2°). The disbursement is more demanding in formalism and remains a minority case for an HR consultant: most expenses are rebilled as accessories, with VAT.

An HR consultant who is starting out may fall under the VAT base exemption, which dispenses with charging and declaring the tax. In 2026, the threshold for services is 37,500 € of turnover, with an upper threshold of 41,250 €. Beyond that, you become liable for VAT.

Being in the exemption is not always an advantage: a consultant who invests (equipment, subcontracting, software) recovers no VAT on purchases while in the exemption. A voluntary switch to VAT can therefore make sense from the start. We analyse this trade-off in our dedicated article on the VAT base exemption, and the overall cost of the structure in our guide on the day rate and charges of the independent consultant.

In the HR consultant files we support, the most common mistake is not a wrong VAT rate but a wrong qualification of the service. Presenting a consulting engagement as training to take it out of VAT, without an attestation or a genuine link to continuing training, is the most frequent reassessment.

Our recommendation is to reason by flow, not by client. Within the same commercial relationship, clearly isolate what is attested training (exempt) and what is consulting, audit or recruitment (taxable). Issue separate invoices or separate lines, with the correct wording. This billing discipline, more than any optimisation, is what secures the activity over time.

Finally, only request the DREETS attestation if training is a genuine part of your offer. For a consultant who mainly does consulting and a little occasional training, the weight of the training-provider status (declaration number, report, attestation) often exceeds the gain of the exemption.

Take an HR consultant who carries out, over a quarter, a combined engagement for an SME: a payroll-function audit billed 12,000 € excluding VAT and a management training cycle billed 6,000 €, the latter covered by a DREETS attestation.

The audit, taxable, bears VAT of 2,400 € (20 % of 12,000 €), bringing the invoice to 14,400 € including VAT. The training, exempt, is billed 6,000 € without VAT, with the wording "VAT exempt, art. 261-4-4° of the CGI". A deposit of 30 % on the audit, that is 3,600 € excluding VAT, collected in January, makes VAT of 720 € chargeable on the January return, without waiting for the end of the engagement after three months.

If that same consultant had, two years earlier, billed everything without VAT thinking it could all be tied to training, the reassessment would have covered the 2,400 € of VAT on the audit, plus late-payment interest. Correct allocation from the outset avoids that risk.