Claiming a VAT credit refund: procedure and deadlines in 2026

Quick answer. A refundable VAT credit arises when deductible VAT exceeds collected VAT and the credit cannot be offset against future returns. Threshold: €760 in the normal scheme (monthly/quarterly), €150 in the simplified scheme (annual). File form 3519-SD (CERFA 11255*17) with your CA3 or CA12 return. Deadline: 31 December of year N+2. Late refunds carry statutory interest; a refusal is possible and must be reasoned.

VAT credit refunds follow strict rules, tiered by your tax regime and the nature of the credit. Until 31 August 2026, the French Tax Code (CGI) applies. From 1 September 2026, a major recodification migrates all VAT provisions to the new Code on Taxes on Goods and Services (CIBS) (Ordinance no. 2025-1247 of 17 December 2025). The refund procedure remains substantially unchanged, but article numbers will shift, creating a transition window in the second half of 2026 worth watching.

In our advisory practice at Hayot Expertise, we regularly see three profiles: the exporter (structural credit, regularly offset and refunded), the fixed-asset investor (one-off but significant credit), and the exempt-supply or hybrid operator (partial credit, with a non-deductible portion). Knowing your profile before filing speeds up processing and reduces the risk of rejection.

Carried-forward credit: the first stage#

VAT works through successive deductions: each business collects VAT on sales and deducts VAT paid on purchases and investments. If deductible VAT exceeds collected VAT over a period, the business holds a credit balance: the carried-forward VAT credit.

This credit is not refunded immediately. The business carries it forward on later returns, offsetting it against future VAT due. Over twelve to twenty-four months it usually runs out, as the business re-balances its collections and deductions.

Example. A trading SME files a February 2026 CA3 with €8,000 of deductible VAT and €3,000 of collected VAT, a carried-forward credit of €5,000. In March it offsets that €5,000 against its March VAT and clears part of the credit. If it generates new credit in April and May, it carries the balance forward.

Refundable credit: the second stage#

When a credit cannot be fully offset in the following months (export sector, exempt operations, heavy investment), the business may request a refund from the tax authority. That is where the formal procedure begins.

A credit becomes refundable only if it:

1. genuinely exists: deductible VAT exceeds collected VAT, evidenced by accounting records and invoices;
2. meets the threshold: €760 in the normal scheme, €150 in the simplified scheme (annual);
3. cannot be offset: either because the activity generates little or no output VAT (exporters, exempt services), or because the credit is structural and durable.

Normal scheme (monthly or quarterly CA3)#

Threshold: €760 minimum. Frequency: monthly or quarterly refund possible (same period as the CA3). Procedure: form 3519-SD is filed with the CA3 of the month or quarter in which the credit arose.

Example. A construction subcontractor files a January 2026 CA3 with €12,000 of deductible VAT (equipment and supplies) and €2,000 of collected VAT, a credit of €10,000. In February and March, activity does not pick up fast enough to reabsorb the credit. The contractor files form 3519-SD with the January CA3 and requests an immediate refund of €10,000. If approved, the transfer arrives a few weeks later. During that time, the credit is not offset against the February CA3.

Simplified scheme (annual CA12)#

Threshold for the annual refund: €150 minimum. Threshold for a mid-year refund (fixed assets): €760 minimum. Annual procedure: form 3519-SD is attached to the CA12 (annual adjustment return), filed by the second business day following 1 May.

Mid-year refund (fixed assets). If the business acquires a heavy fixed asset (machinery, vehicle, real property) generating a VAT credit of at least €760, it can claim a refund without waiting for the year-end CA12.

Example. A joinery on the simplified scheme buys a CNC lathe for €180,000 excluding VAT in April 2026, i.e. €36,000 of VAT. With a large credit and tight cash, it claims a mid-year refund. If approved, it receives the funds before the summer and finances the balance of the equipment with its supplier.

Business under the VAT exemption (no output VAT)#

Businesses under the VAT exemption (2026 thresholds: €37,500 for services, €85,000 for trade) do not charge VAT and therefore generate no refundable credit. If they cross the threshold, they become VAT-liable from the month of the breach and fall under the simplified or normal scheme depending on turnover. Any credit then follows the rules of the applicable scheme.

Step 1: document the credit and its accounting basis#

You must hold all supporting documents for the operations generating the VAT credit.

• Deductible VAT on goods and services: purchase invoices (date, net amount, VAT, gross total, supplier registration number), proof of payment if the supplier is outside the EU.
• VAT on fixed assets: the asset purchase invoice, related installation invoices, proof of accounting entry.
• VAT on external services (consulting, maintenance, subcontracting): the supplier invoice and proof the service was delivered.

On audit, the authority first checks that every invoice underlying the credit is real, correctly stated and properly recorded as deductible VAT. A missing or inconsistent invoice triggers an adjustment; a doubt about authenticity can hold up the claim for months.

Practical advice. Build a VAT credit file: a numbered invoice schedule, a monthly or quarterly summary, a reconciliation to the CA3 or CA12, and a worksheet showing the balance before and after. This speeds up processing.

Step 2: complete form CERFA 11255*17 (form 3519-SD)#

The official form is CERFA no. 11255*17, "Request for refund of tax credits (VAT and allied taxes) — normal and simplified scheme".

If the credit stems from a first-ever return (the first month after incorporation), flag it: this routes the claim to a specific review process.

Step 3: assemble the file and submit#

Documents to attach: the signed form 3519-SD, the signatory's ID, the CA3 or CA12 copy evidencing the credit, the detailed invoice schedule, the purchase and service invoices, the fixed-asset invoices where relevant, and proof of payment if requested.

Filing mode (2026). Online, preferably, via the impots.gouv.fr business portal; or by registered mail to the competent corporate tax office.

Filing deadline (a crucial rule). No later than 31 December of the second year following the year the credit arose. A credit arising in 2026 must be claimed before 31 December 2028. A late filing is rejected, with no reconsideration.

Step 4: track processing and respond to requests#

Processing usually takes three to six months for a standard claim, and up to twelve months where there is complexity or sectoral doubt.

The authority may request additional documents (missing invoices, contracts, attestations). You have a set period to reply; otherwise the claim may be closed. A prior or concurrent claim under review may be consolidated.

The refund may be full, partial (for example where part of the credit relates to an ineligible exempt sector) or denied by a reasoned decision.

Statutory interest. If the authority is late in refunding, you can claim statutory interest at the legal rate. This interest is not automatic: you must request it expressly.

Exporters and cross-border B2B operators#

An exporter of goods (outside the EU) or a provider of services to foreign clients deducts VAT on purchases and investments but collects no VAT on sales (export exemption or reverse charge by the customer). The structural credit arises regularly, and these businesses claim refunds periodically to ease cash flow.

Fixed-asset investors#

An SME making a heavy investment (machinery, infrastructure) generates a one-off but very significant VAT credit. It can claim a refund immediately to fund part of the acquisition.

Exempt operators (banks, insurers)#

Banks and insurers operate under an exemption on most of their activity: their purchases bear VAT, but no VAT is collected. The resulting credit cannot be offset and is refunded regularly. Where a taxable side activity exists (a property let for consideration, say), separate accounting between exempt and taxable activities governs the refundable share.

VAT credit and VAT group#

If your group is under the VAT group regime, a single refund claim covers the whole perimeter. The aggregate amount can be large, which justifies a longer review. The group representative signs form 3519-SD.

VAT credit and the exemption#

A business under the VAT exemption cannot claim a refund, as it is not VAT-liable. If it crosses the exemption threshold, VAT becomes chargeable from the month of the breach; it can then generate credits.

VAT credit in the first year#

A business set up during the year that generates a structural credit early (buying equipment before its first sales) must watch the filing deadline. A credit arising in July 2026 must be claimed before 31 December 2028. File the claim with a short note explaining the project.

CIBS recodification of September 2026#

From 1 September 2026, VAT references move from the CGI to the Code on Taxes on Goods and Services (Ordinance no. 2025-1247 of 17 December 2025). The refund procedure stays the same, but article numbers change. If you file form 3519-SD before September 2026, cite the old CGI numbering; from September, check the updated reference. The 3519-SD form itself remains valid.

At Hayot Expertise, a firm registered with the Ordre des experts-comptables, a refundable VAT credit is much more than a tick-box: it is a cash-flow line that, well managed, can release hundreds of thousands of euros, and, poorly managed, locks up funds for months and triggers collateral audits.

We recently advised a construction subcontractor (35 staff, €8.5m turnover, on the normal monthly scheme) after it bought three excavators and two compressors, for a VAT credit of €116,000. The file submitted with that month's CA3 carried complete, named invoices and a concise two-page summary. The claim was approved in full and the refund received three months later. By contrast, another firm in the same sector had built up its credit from a multitude of small suppliers with patchy documentation: the claim was suspended for several months, then only partly approved after verification.

The field lesson is simple: a real, documented, concise file is refunded quickly; a scattered file is paid for in months of waiting. Number and archive every significant invoice at purchase, reconcile deductible VAT to invoices received at each month-end, and have the file reviewed before submission.

Hayot Expertise advice. A refundable VAT credit is public money owed to you, provided you claim it in the right form and within the deadline. Missing the 31 December N+2 deadline means a permanent loss; filing without the invoices means rejection and a re-filing months later. We recommend acting as soon as the credit forms: a complete, backed-up file submitted within two to three months. Also prepare for the September 2026 CIBS recodification if your credit recurs.