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As from 1 January 2027, several VAT exemptions currently provided for under Article 261 C, 1° of the French Tax Code will, under the CIBS, be subject to statutory definitions and general criteria incorporating into French law principles that have, until now, primarily stemmed from European case law and, in certain instances, have already been reflected in the French tax authorities’ administrative guidelines.

CJEU French salaries payroll dividends tax

Redrafting and integration of French VAT legislation into the new CIBS code: implementation postponed to 1 January 2027

In a decision of 13 May 2026 (Stellantis Portugal, C-603/24), the CJEU ruled again on the connection between transfer pricing adjustments and VAT