Transfer of VAT to CIBS: Interview with Grégoire PERSON on B Smart

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Grégoire Person, lawyer and co-founder of Cyplom Avocats, recently intervened to analyze and decipher a major VAT reform: the transfer, starting from September 1, 2026, of all the provisions relating to value added tax of General Tax Code towards a new autonomous corpus, the Code of taxation on goods and services (CIBS).

A major reform, with constant law but with concrete effects

This reform, led by the Department of Tax Legislation, officially aims at recodification “at constant law”. However, as Grégoire Personon pointed out, if the substantive rules are not supposed to change, the complete rewriting of texts, the adoption of a New plan, as well as the introduction of a Unpublished vocabulary, have important practical consequences for businesses and their advice.

More than 1,000 items have been drafted, making a significant phase of ownership necessary for VAT practitioners, an already technical and highly specialized field.

Support tools and consultation phase

The tax administration has provided several tools to facilitate the transition, including a Correspondence table between the old articles of the CGI and the new provisions of the CIBS, as well as the gradual publication of a updated administrative doctrine (BoFIP).

One consultation phase is also open in order to collect feedback from companies and practitioners, the administration being aware of the particularly complex and transversal nature of this project.

Operational impacts not to be underestimated

Beyond the codification change, Grégoire Person insisted on the fact that the reform integrates directly into the law some European case law, hitherto absent from French texts. This integration reinforces legal certainty, but may also lead to the effective application, in France, of solutions that have hitherto been little or not implemented in practice (in particular in terms of leasing or real estate VAT on margin).

Businesses must therefore go well beyond a simple exercise in “renumbering” articles: some tax regimes need to be analyzed and adapted.

A reform to be combined with electronic invoicing

This recodification comes in an already busy context, marked by the rise in power of electronic invoicing. The questions of mandatory information on invoice, especially in the case of exemptions or specific regimes, should be treated carefully.

Although administrative tolerance is planned until the end of 2027 for the use of old references to the CGI, it is recommended, according to Grégoire Personon, to favor whenever possible the references to European law, more stable over time.

Anticipating and training: a key challenge for businesses

In conclusion, this reform is a significant effort to clarify and modernise, but it also creates new difficulties in accessing the law, in particular because of the terminological distance from European law.

Businesses are therefore invited to anticipating, to To be formed, and to be supported in order to secure their VAT practices in this new legal framework, which will be fully applicable as of September 1, 2026.