VAT on training sold abroad: the rules for a French provider going international
You obtained your VAT exemption under article 261-4-4°a of the CGI, your French invoices are in order — and then a prospect based in Belgium, or an individual in Quebec, signs up for your next remote session. Should you charge 20% VAT? Does the French exemption still apply? The answer depends on two distinct questions that many organisations conflate: where is VAT due, and is it exempt once that country is determined. Here is how to find your way before your first international sale.
Two questions not to mix up
VAT territoriality (which country the tax is due in) and the exemption under article 261-4-4°a of the CGI are two independent mechanisms. The second only kicks in once the first designates France as the country of taxation. As soon as a client is based abroad, the question to ask first is not “am I exempt?” but “is French VAT even relevant to this sale?” If you haven’t yet applied for the exemption on your French sales, our article on the VAT exemption for a French training organisation covers the procedure and form 3511-SD.
Selling to a business in the European Union (B2B)
For a training service billed to a business client established in another EU member state, the general territoriality rule (article 259-1° of the CGI) applies: VAT is due in the client’s country, not in France. In practice:
- you invoice without tax, with the wording “Reverse charge — article 283-2 of the CGI” (or a reference to article 196 of directive 2006/112/EC);
- the client self-assesses VAT under their own country’s rules;
- you must hold the client’s valid intra-EU VAT number (verifiable via the European Commission’s VIES service) and show it on the invoice;
- these transactions must be declared monthly via the DES (European services declaration) to French customs.
This rule applies regardless of the training format (in-person, virtual classroom, e-learning): for B2B, it is the client’s professional status that determines the country of taxation, not how the training is delivered.
Selling to an individual in the European Union (B2C): it all depends on the format
This is where confusion is most common, since two regimes coexist depending on the exact nature of the service.
Automated training, without live human involvement (pre-recorded e-learning module, self-correcting quizzes, access to a platform without synchronous support): this qualifies as an electronically supplied service under EU VAT rules. VAT is due in the consumer’s country, via the OSS (One Stop Shop) one-stop-shop regime.
Training led live by a trainer (an interactive virtual classroom run in real time): under EU VAT Committee guidance, substantial human involvement rules out the “electronic service” qualification. The general B2C rule then applies: VAT remains due in the provider’s country, i.e. France — with your 261-4-4°a exemption applying where obtained, exactly as for a French client.
A common threshold governs the OSS regime: below €10,000 of combined annual turnover across all your distance sales and electronic services to EU individuals, you can keep applying French VAT. Above it, registering for the one-stop shop becomes necessary to declare and remit the VAT due in each of your clients’ countries, through a single quarterly return on your professional impots.gouv.fr account.
Selling outside the European Union: exports
For a business client established outside the EU, the service is generally outside the scope of French VAT (non-taxable transaction, article 259-1° of the CGI): you invoice without VAT, stating this explicitly on the invoice. For an individual located outside the EU, treatment depends on the exact nature of the service and may fall under the destination country’s local tax rules (some countries themselves tax imported digital services) — a point to confirm with your accountant before developing this segment, as rules vary significantly from one non-EU country to another.
Summary: what to state on the invoice
| Situation | VAT due where? | Wording to use |
|---|---|---|
| Business client, EU (B2B) | Client’s country | “Reverse charge — article 283-2 of the CGI” + client’s intra-EU VAT number |
| Individual, EU, automated e-learning, below the €10,000 threshold | France | French VAT (or 261-4-4°a exemption if obtained) |
| Individual, EU, automated e-learning, above the threshold | Client’s country | Local VAT declared via the OSS |
| Individual, EU, live virtual classroom | France | French VAT (or 261-4-4°a exemption if obtained) |
| Business client, outside the EU | Outside scope | “Transaction not taxable in France — article 259-1° of the CGI” |
| Individual, outside the EU | Varies by country | To confirm based on local tax rules |
The intra-EU VAT number, even under the VAT exemption threshold
One point that often surprises micro-entreprise organisations: even under the French “franchise en base” VAT exemption threshold (so without charging VAT in France), a B2B sale to a business client in the EU still requires obtaining an intra-EU VAT number from your local business tax office (SIE), to correctly apply the reverse charge and file the European services declaration. It is a free, quick process, but one to handle before your first export invoice rather than after.
Why this is worth planning ahead, not reacting to
A review of the academic literature on VAT compliance costs, published by S. Vishnuhadevi in the Review of Development and Change (2021), shows that these costs weigh proportionally heavier on small structures than on large companies, since a large share is fixed and independent of turnover (study on Google Scholar). For a sole-practitioner training organisation, or a small structure starting to sell abroad, this has a very concrete implication: it is worth clarifying your invoicing logic once, by client type (B2B/B2C, EU/non-EU, training format), rather than correcting dozens of mis-qualified invoices after the fact.
Take action
Growing your activity internationally requires solid administrative and tax foundations from the start. The Complete Kit Certif (€297, 14-day guarantee, documents in French) provides the procedures and evidence tables for the 32 indicators to structure an organisation ready to grow, and the ebook Créer son organisme de formation en 30 jours (€67) details the administrative and tax steps of setting up a French training organisation, from the activity declaration to the first invoice — both bundled in the complete pack at €347.
Frequently asked questions
+Does my VAT exemption (article 261-4-4°a of the CGI) also apply to my foreign clients?
It only applies if France is the country where VAT is due. For a business client in the EU, the tax is due in the client's country (reverse charge): the French exemption is simply not relevant, since the transaction is not subject to French VAT in the first place. For in-person or live sessions billed to a French individual, the exemption keeps applying as normal.
+Above what turnover do I need to register for the OSS one-stop shop?
Above €10,000 of combined annual turnover across all your distance sales and electronic services to individuals in the European Union, registering for the OSS one-stop shop becomes necessary to declare the VAT due in each of your clients' countries. Below that threshold, you can keep invoicing with French VAT.
+Does a live virtual classroom with a trainer follow the same rules as a recorded e-learning module?
No, and this is a genuine tax distinction. An automated e-learning module, without significant human involvement, is an 'electronically supplied service' subject to the OSS regime for EU individuals. A virtual classroom run live by a trainer does not fall into that category: it follows the general B2C rule, with VAT due in France as for an in-person course.
+Do I need to charge VAT to a client located outside the European Union?
For a business client established outside the EU, the service is generally outside the scope of French VAT: state on the invoice that the transaction is not taxable in France (article 259-1° of the CGI). For an individual outside the EU, treatment depends on the nature of the service and may fall under the client's local tax rules — a point to check with your accountant before your first export sales.