A French freelance developer or small web agency who stays under the VAT exemption threshold invoices French clients net of tax without a second thought. The moment a client is based elsewhere in the EU, that simplicity ends: an intra-EU VAT number, a reverse-charge mention and a European services declaration all come into play, even for an invoice worth a few hundred euros.
The habit to unlearn: the VAT exemption doesn’t cover everything abroad
In 2026, France’s VAT exemption threshold (franchise en base) applies up to €37,500 in annual turnover for services, with a tolerance ceiling of €41,250. Below that, no VAT is charged to French clients, and none paid on purchases can be reclaimed. That regime still holds for French clients, whether the freelancer operates as a sole trader or a single-member company. It does not, however, remove the need for an active intra-EU VAT number, nor the obligation to declare services sold to professional clients in another member state.
The intra-EU VAT number: reactivate it before the first invoice
An intra-EU VAT number (VIES number) is assigned at business creation, derived from the SIRET, but stays inactive for a micro-entrepreneur under the VAT exemption until a specific request is made. As soon as a service is sold to a business client established in another member state, or once €10,000 in intra-EU acquisitions is exceeded in a year, the number needs reactivating with the relevant tax office (SIE), before the invoice in question is issued. Without an active, verifiable number, the invoice cannot correctly state the reverse charge, and the client may reject it.
Invoicing a business client in the EU (B2B): the reverse-charge rule
For a service sold to a business client (B2B) established in another EU country, the default rule places the place of taxation in the client’s country, regardless of the amount involved. The invoice is issued net of French VAT, carrying a reverse-charge mention. The client then declares and pays VAT locally, at their own country’s rate. This rule applies from the first euro, including for a freelancer under the VAT exemption threshold.
| Situation | VAT on the invoice | Declaration required |
|---|---|---|
| Business client in France | None (VAT exemption) | No specific declaration |
| Business client elsewhere in the EU (B2B) | None, reverse-charge mention | Monthly DES, from the first euro |
| Private individual elsewhere in the EU (B2C, electronic services) | Client’s country VAT once €10,000 in cumulative annual EU sales is exceeded | One-Stop Shop (OSS) once the threshold is crossed |
| Client outside the EU | None, out of scope of French VAT | No DES |
The European services declaration, mandatory from the first euro
Every service sold to a taxable business client in another member state must be reported through a European services declaration (DES), filed monthly with French customs. This obligation applies from the first euro billed, including for a business under the VAT exemption: not collecting VAT oneself does not remove the need to declare that the client owes it under reverse charge. Missing this can draw a fine of up to €750.
The DES is filed per service delivered, not per invoice paid or deposit cashed: it’s the date the service was performed that determines which month it belongs to, not the payment date.
The case of private individuals in the EU (B2C)
For a private client based elsewhere in the EU, the logic shifts. A standard development service generally still falls under French VAT, except for services delivered electronically (access to an app, digital content, and the like), which switch to the client’s country VAT once cumulative EU sales to individuals exceed €10,000 a year. Past that threshold, the One-Stop Shop (OSS) allows declaring and paying that foreign VAT without registering in every country involved.
What must appear on the invoice
A correct B2B intra-EU invoice carries the supplier’s intra-EU VAT number, the client’s (verified, not just copied over), and an explicit reverse-charge mention, such as “Reverse charge, Article 283-2 of the French Tax Code” or “VAT exempt, Article 262 ter of the French Tax Code” depending on the case. A business still under the VAT exemption adds the usual “VAT not applicable, Article 293 B of the French Tax Code” mention, which coexists with the reverse-charge mention when both rules apply at once. These requirements stack on top of those already introduced by e-invoicing, and are best set once in one’s invoicing tool rather than re-typed on every send.
The European services declaration kicks in from the first euro billed to a business client in the EU, even when no VAT is collected: the obligation doesn’t depend on the supplier’s VAT regime, but on where the client is based.
Verifying the client’s VAT number before issuing the invoice
Applying the reverse charge assumes the client genuinely holds a valid intra-EU VAT number, not just a SIRET or a local registration number that looks like one. Verification runs through the European Commission’s VIES system, which confirms within seconds whether a number is active and, in some countries, whether it matches the stated company name. An invalid number at billing time, even if corrected later, risks having to re-charge French VAT if the tax authority decides the reverse-charge conditions weren’t met when the service was performed. Keeping a timestamped screenshot of the VIES check, alongside the number itself, saves having to reconstruct that proof months later during an audit.
Common mistakes
The most frequent confusion is treating an EU client like a French one simply because no VAT was being collected anyway under the exemption, forgetting that the DES is still due. Next comes the B2B/B2C mix-up: a client ordering from a personal email address isn’t necessarily a private individual, which is checked through the presence of a VAT number and a business registration. Finally, many freelancers discover the DES obligation months into working with an EU client, at the point of an audit or a nudge from their accountant, when retroactive filing remains possible but far heavier than a monthly declaration kept up from day one.
Key takeaways
Selling to a business client in the EU changes nothing about the amount billed for a freelancer under the VAT exemption, but adds two steps that don’t exist for a French client: an active, verified intra-EU VAT number, and a monthly European services declaration. Private individuals follow a different logic, with a €10,000 threshold that only concerns electronic services. Mixing up the two regimes is the most frequent mistake, and the most expensive to fix after the fact.
This is one of those administrative steps I recommend handling once and for all from the first client outside France, rather than waiting until it’s urgent: reactivating the intra-EU VAT number takes a few days, and it’s better to have them ahead of you than behind an invoice already sent. — Simon Janvier
Primary source: French Customs, “La déclaration européenne de services (DES)”.
