Physiotherapist in a SEL: retrocessions, collaboration and tax return

Quick answer. For a physiotherapist, the retrocession from an occasional replacement stays VAT-exempt, but the collaboration redevance is subject to 20% VAT because it pays for the use of furnished premises and equipment. Only these redevances count toward the 37,500-euro VAT exemption threshold in 2026.

In physiotherapy practices, confusing the collaboration redevance with the fee retrocession is one of the costliest mistakes we see. Both flows involve sums paid between practitioners, but their VAT treatment and bookkeeping differ radically. Mislabelling these flows exposes the owner to uncollected VAT and the collaborator to an improperly deducted expense.

This issue is distinct from the choice of structure. If you are still hesitating between individual practice and a company, first read our analysis to choose between BNC and SEL for a physiotherapy practice. Here, we deal with collaboration flows once the structure is in place.

The physiotherapist is a regulated allied-health professional. Their care procedures are VAT-exempt under the French Tax Code, article 261, 4-1°. This exemption covers care, not the internal flows between practitioners.

Three arrangements coexist in practice, and each calls for a different treatment.

Replacement means practising in place of the absent owner, retroceding a percentage of the fees collected. Liberal collaboration, governed by Law no. 2005-882 of 2 August 2005, article 18, assumes the collaborator has their own patient base and practises in the owner's premises in exchange for a redevance. Assistantship or salaried work follow yet another logic, with an employment contract.

Our reading. The dividing line is not the name of the contract, but its economic reality. A replacement that drags on month after month stops being occasional: the tax authorities may then reclassify the retrocession as a taxable redevance. We recommend setting the nature of the relationship in writing from the start and reviewing it every year.

The VAT treatment is set out in the BOFiP, reference BOI-TVA-CHAMP-30-10-20-10. It draws a clear distinction.

The fee retrocession paid for a replacement of an occasional nature is VAT-exempt. This is an administrative tolerance, applicable as long as the replacement stays one-off.

The collaboration redevance is subject to VAT at the standard 20% rate. The reason is clear: it pays for the provision of furnished professional premises and equipment, a service distinct from care. The same reasoning applies as soon as a replacement becomes regular or permanent.

The logic of taxable redevances is not specific to physiotherapy. It is found in other liberal professions: see the treatment of collaboration redevances in liberal professions among lawyers, whose mechanism is analogous.

VAT exemption: only the taxable fraction counts#

A key point for the owner receiving redevances: only the taxable fraction, that is the redevances, enters the assessment of the VAT exemption threshold. Exempt care never enters it.

The 2026 VAT exemption threshold for services stands at 37,500 euros, with an upper limit of 41,250 euros (Tax Code, article 293 B). Law no. 2025-1044 of 3 November 2025 maintained these thresholds and dropped the planned single threshold of 25,000 euros.

The underestimated risk. Many owners reason on their total turnover, care included, and conclude they exceed any VAT threshold by far. This is an analytical error: as long as your collaboration redevances alone stay below 37,500 euros, you can invoice them under the exemption. Conversely, a practice with several collaborators may cross the threshold on redevances alone without noticing, and become liable for 20% VAT.

A physiotherapy practice we support in Paris had been invoicing a monthly redevance to its collaborator for two years without ever mentioning VAT, believing that the exemption on care covered everything. The cumulative redevance amount had crossed the threshold. The adjustment covered the undeclared output VAT, with interest. A simple distinction at the outset would have avoided this catch-up.

In practice. Here is the procedure we apply in our collaboration files.

1. Qualify the relationship in writing: replacement, collaboration or assistantship, with the agreed percentage or amount.
2. Check whether the redevance is taxable and, where applicable, track the annual cumulative figure against the 37,500-euro threshold.
3. The owner issues a redevance invoice, mentioning 20% VAT when it is due.
4. The replacing practitioner issues a dated retrocession statement, backed by the fees collected.
5. Keep the contract, fee statements and invoices to trace each flow and support the return.
6. Reconcile the flows monthly in your accounting tool.

A connected accounting tool such as Pennylane makes this monthly reconciliation and the tracking of cumulative redevances against the VAT threshold easier. For full bookkeeping and review, our team handles the bookkeeping and review of your BNC accounts.

The bookkeeping sits within the framework of the BNC controlled return no. 2035.

For the owner, the redevance received is income; it carries output VAT when subject to tax. For the collaborator, the redevance paid is a deductible expense, recorded as collaboration redevances, while their gross fees are their own income.

Fee retrocessions, for their part, appear on the dedicated line of the 2035 return, separate from redevances. This breakdown drives the consistency of your return. Our physiotherapist accounting guide details the structure of the BNC accounts specific to the profession.

Trade-off. Between staying in individual BNC practice and moving to a SELARL or SELAS, collaboration is not neutral. The SEL, subject to corporate income tax, makes the manager's remuneration and the self-employed social contributions of the majority manager parameters to weigh. Collaboration remains possible in both frameworks, but its bookkeeping changes: in BNC, the redevance is an expense on the 2035; in a SEL, it forms part of the company's income statement. The choice depends on your income level and your wealth plan, a subject we discuss with you when you consider setting up your practice structure.

Points of vigilance 2026. Two subjects come up systematically in our year-end reviews.

The DAS2 first. Fees, commissions and retrocessions paid to a third party must be declared via the DAS2 when they exceed 2,400 euros incl. VAT per beneficiary per year. This threshold was doubled, raised from 1,200 to 2,400 euros, for sums paid since 2024. The electronic filing takes place before 31 January of the following year. An owner who pays a significant retrocession to a replacing practitioner is concerned, and forgetting this return is sanctionable.

The OGA next. The 25% surcharge for not joining an approved management body has been abolished since the taxation of 2023 income, after a gradual phase-out provided for by the 2021 finance act (Law no. 2020-1721 of 29 December 2020, article 34). Joining an OGA is therefore no longer justified by this former surcharge. The residual benefit is the income-tax reduction for accounting fees, reserved for members meeting the conditions.

What the tax authorities look at. On collaboration, the inspector focuses on the consistency between the declared nature of the flow, its VAT regime and its bookkeeping. A redevance described as collaboration but treated as an exempt retrocession draws attention, as does a permanent replacement kept under the exemption. To secure these points, we can secure the tax treatment of your flows before the closing.

Preparing the 2035 and DAS2 is better anticipated than reconstructed in March. For individuals concerned by the income tax return, also find the 2026 income tax return calendar.

Our firm is registered with the Order of Chartered Accountants of Ile-de-France and supports liberal healthcare professions on the qualification of these flows. Discover our support for physiotherapists for guidance tailored to your practice.