There is a clear movement for tighter documentation, stricter control of VAT exemptions, and reduced reliance on historical simplifications for non-EU operators.
What has changed
The bulletin clarifies and updates declarative VAT rules in three key areas:
- VAT-exempt imports under article 275 of the French Tax Code
- Supplies of goods while under customs suspension under article 277 A
- Import VAT exemptions where goods are immediately dispatched intra-EU under Regimes 42 and 63
Why this matters for non-EU Yachts
1. Importation into France
Any non-EU flagged yacht physically entering French customs territory must be considered from a VAT perspective. Scenarios include:
- Permanent importation into the EU
- Sale of a non-EU yacht to an EU buyer
- Transfer of beneficial ownership to an EU resident
- Change in intended use
- Movement from Temporary Importation to free circulation
From 1 January 2026, non-EU entities will no longer be able to rely on third-party VAT numbers to use this regime. The importing entity must hold its own French VAT registration. This is highly relevant for offshore yacht owning SPVs.
For yachts valued in the tens of millions, the financial exposure is obvious.
2. Sales while located in France
France remains a major hub for yacht transactions. If a non-EU yacht is sold while physically in France, customs status must be addressed immediately.
The new bulletin tightens DELTA-I declaration requirements and documentary chains supporting VAT exemptions. Poor coordination between brokers, customs agents and corporate administrators increases the risk that a sale may inadvertently trigger French import VAT.
Ownership changes without proper customs treatment can crystallise VAT unexpectedly.
3. Refit and Yard activity
French shipyards in Antibes, La Ciotat and Marseille handle a significant portion of Europe’s large-yacht refit market.
Where parts or equipment are supplied under customs suspension regimes, article 277 A now requires stricter reporting and supporting evidence in customs declarations.
Incorrect coding or documentation may result in loss of VAT suspension treatment. Given the scale of refit projects, this creates material financial risk.
Even yachts not under Temporary Importation may be affected if equipment movements are not properly structured.
4. Charter and cross-border operations
Non-EU yachts engaged in charter activity that operate between France, Monaco and other EU jurisdictions must ensure:
- Consistent customs status
- Correct VAT registration of owning entities
- Proper treatment of importation and onward movements
A Broader Enforcement Trend
This bulletin should be viewed as part of a wider shift in French VAT administration:
- Greater traceability in DELTA-I declarations
- Reduced tolerance for third-party VAT number usage
- Enhanced verification of intra-EU dispatch evidence
- Stronger alignment between customs and VAT authorities
Practical steps for owners and brokers
- Review the VAT and customs status of the yacht before any sale
- Assess whether the owning SPV requires French VAT registration
- Plan importation strategies well in advance
- Coordinate closely with customs brokers before refit or structural changes
- Map out the VAT consequences of ownership changes
Rosemont Yacht Services
As a Trust and Corporate Services Provider specialising in superyacht structures, Rosemont Yacht Services assists owners, brokers, captains and advisers in managing the corporate and regulatory framework surrounding yacht ownership.
Our role includes:
- Administration of yacht owning SPVs
- Coordination with VAT and customs specialists
- Oversight of beneficial ownership changes
- Governance and compliance management
- Cross-border structuring support
If you would like to review your structure in light of the latest French developments, our team would be pleased to assist: rys@rosemont-yacht.com
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03/2026