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I am a jewelry manufacturer and I sell wholesale to retailers: am I subject to the HBJOAT tax?

Short answer

Yes. As a jewelry manufacturer, you are liable for the HBJOAT tax on your sales of taxable products to retailers or other professionals.

The fact that you sell wholesale and not directly to consumers does not exempt you from the tax. Francéclat indicates that deliveries made by manufacturers are taxable.

Why are the manufacturer's wholesale sales taxable?

The simple wholesale resale of products purchased and then resold as is is not taxable. However, this exemption does not apply to products manufactured by the company itself.

The Goods and Services Tax Code considers the following to be involved in manufacturing:

  • the company that produces, manufactures or assembles the product in France; ;
  • the company established in France which has the product manufactured by a third party by supplying the raw materials; ;
  • the company that specifies the plans, drawings, models, techniques or product characteristics; ;
  • the company that affixes or has affixed its own brand to the product.

Wholesale: Who pays the tax?

When a manufacturer sells a new, taxable piece of jewelry to a retailer:

  • the manufacturer declares the tax on the pre-tax price of its sale to the retailer; ;
  • The retailer then declares the tax on the pre-tax price of their sale to the end consumer.

There is no deduction mechanism comparable to that of VAT. The HBJOAT tax is mandatory and non-refundable.

Concrete example

A manufacturer sells a new piece of jewelry to a jewelry store for €1,000 excluding VAT.

The tax payable by the manufacturer is:

€1,000 × 0.19 % = €1.90

The jewelry store then resells this piece of jewelry for €1,800 excluding VAT to a private individual. It then calculates the tax on its own selling price excluding VAT:

€1,800 × 0.19 % = €3.42

Which of the manufacturer's sales are taxable?

For a manufacturer established in France, the following deliveries of the products in question are taxable:

  • In France ;
  • to a Member State of the European Union; ;
  • to Iceland, Liechtenstein or Norway; ;
  • to Great Britain or Northern Ireland.

Exports to other territories outside this perimeter are not subject to the HBJOAT tax.

Calculation basis

The tax is calculated at the rate of 0,19 % on the turnover excluding VAT corresponding to the taxable transactions and products.

Therefore, it is important to distinguish between the following in your accounting:

  • sales subject to tax; ;
  • non-taxable exports; ;
  • any potential services, which are excluded; ;
  • sales of products not included in the official list of taxable products.

How to declare?

The declaration and payment are made on teletaxe.fr.

The frequency depends on the amount of tax due the previous year:

  • over €1,000: monthly declaration; ;
  • from €200 to €1,000: quarterly declaration; ;
  • less than €200: annual declaration.

When the annual amount of the tax is less than or equal to €20, the company is exempt from payment, but remains required to make its declaration.

Official sources

  • Articles L. 471-22 and L. 471-23 of the Code of Taxation on Goods and Services
  • Article 56 of Decree No. 2021-1914 of December 30, 2021
  • Francéclat and teletax.fr
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