Invoicing a foreign client: mentions, VAT and proof of export or delivery

Quick answer. The VAT regime of an invoice abroad depends on three questions: are you selling a good or a service, to a business or a consumer, in the European Union or outside the EU? A supply of goods to a business in another Member State is exempt (Article 262 ter, I of the French tax code); an export of goods outside the EU is too (Article 262, I); a service to a business established outside France is in principle taxed at the customer's place, by reverse charge. In all cases: check your client's VAT number on VIES, put the right mention on the invoice and keep the proof (transport, customs).

Selling abroad is a growth driver, but VAT follows precise rules that a mere "VAT-free" invoice does not satisfy. A poorly justified exemption can be challenged, with a VAT reassessment and penalties. In parallel, the e-invoicing reform introduces in 2026 an e-reporting of operations with foreign clients and consumers, which we detail regarding e-reporting of international transactions.

Before issuing the invoice, ask yourself three questions:

1. Good or service? Goods and services do not follow the same place-of-supply rules.
2. Business (B2B) or consumer (B2C)? The client's status changes the applicable regime.
3. In the European Union or outside the EU? Export outside the EU and intra-community supply fall under distinct rules.

These three criteria alone determine the VAT treatment and the invoice mentions.

The sale of goods to a taxable person in another Member State is an exempt intra-community supply (Article 262 ter, I of the tax code), on three conditions:

• the buyer is a business identified for VAT in another Member State;
• their intra-community VAT number is valid, which you check on the European VIES service, as we explain for checking an intra-community VAT number;
• you hold the proof of dispatch or transport of the goods out of France.

The invoice bears the mention "VAT exemption, Article 262 ter, I of the French tax code", along with the VAT numbers of the seller and the buyer. The operation is reported in the VAT recapitulative statement (the former goods-exchange declaration, split since 2022).

The sale of goods dispatched outside the Union is an exempt export (Article 262, I of the tax code). The invoice is issued without VAT, with the mention "VAT exemption, Article 262, I of the French tax code". The proof of exemption rests on customs documents: the electronic certification of exit from the Union's territory, or a transport document attesting delivery outside the EU. Without this proof, the exemption can be challenged.

For services between businesses, the general rule places taxation at the customer's place (Article 259, 1° of the tax code). When your business client is established outside France, the service is not subject to French VAT: the customer reverse-charges the VAT in their country. The invoice bears the mention "Reverse charge", with both parties' VAT numbers. For a customer established in the Union, the operation is reported in the European services declaration (DES).

Exceptions exist (services connected to immovable property, certain physical services, events): check the specific rule before applying the reverse charge.

Sales to a consumer (B2C). Distance sales of goods to EU consumers may fall under the OSS one-stop shop, and imported goods under the IOSS: the subject is covered regarding OSS and IOSS VAT flows and, more broadly, VAT in e-commerce.

The invalid VAT number. If your client's intra-community VAT number is invalid on VIES, the exemption of the intra-community supply can be refused: invoice with caution then and regularise the situation.

The missing proof. An export or intra-community exemption without proof of transport or exit is fragile: keep the supporting documents systematically, as for any invoice.

• Check the VAT number on VIES. An intra-community exemption rests on a valid number: verify it and keep the proof of the check.
• Keep transport and customs proof. Without it, the export or intra-community exemption is exposed to a reassessment.
• Use the right mention. The invoice mention must exactly match the regime applied.
• Distinguish B2B and B2C. The client's status changes everything: a consumer does not follow the same rules as a business.
• Anticipate e-reporting. Operations with foreign clients and consumers fall within the scope of the 2026-2027 reform's e-reporting.

Recently, an exporting SME consulted us after invoicing several "VAT-free" supplies to EU clients, without keeping proof of transport or checking the VAT numbers. During an audit, the administration questioned the reality of the dispatches. We reconstructed the available proof and set up a simple procedure: systematic check of the VAT number on VIES, archiving of transport documents, and the exact mention on each invoice. The exemption could be justified, but the situation could have proved costly for lack of proof.

Our conviction, as accountants registered with the Ordre, is that invoicing abroad is not complicated, but does not tolerate approximation. The right mention and the right proof, kept from the moment the invoice is issued, are worth more than a reconstruction under the stress of an audit. It is a point we secure within tax advice, alongside the compliance of electronic invoicing.

Hayot Expertise advice. Before invoicing a foreign client, qualify the operation: good or service, business or consumer, EU or outside the EU. Check your client's VAT number on VIES, put the exact mention (262 ter for intra-community, 262 for export, "Reverse charge" for B2B services) and keep the proof of transport or exit. Finally, anticipate the e-reporting of international operations. An invoice well built from the start saves you any VAT reassessment.