SIREN and E-Filing for Foreign Entities Holding French Property

12 août
9 min de lecture

If a foreign company, trust or similar structure must file France's annual 3% tax declaration (form 2746-SD), it almost always needs a French SIREN number first. Without that nine-digit identifier, you cannot open a professional space on impots.gouv.fr or use the mandatory TVVI teleprocedure. Paper is no longer the normal route.

This guide is the practical sequence: when you need a SIREN, how to register a non-resident entity on the Guichet unique, which documents to attach, how to activate e-filing (EFI or EDI), and why the 2027 reform makes early setup essential. For what goes on the form itself, see Form 2746-SD: The Complete Guide. For the legal change, see French 3% Tax (TVVI): What Changes From 2027.

FrenchNotaires matches you free of charge with vetted bilingual notaires, typically within about 48 hours, in person or by video call. Your notaire can supply title and SCI records that match the ownership chart your tax adviser will upload online.

Why a SIREN is the gate to e-filing

Since assessments linked to property held from 1 January 2021, electronic filing of form 2746-SD (and of any new standing commitment while that route still existed) has been mandatory under CGI Article 1649 quater B quater, XII.

The administration's own FAQ is blunt: to reach the teleprocedure you must create a professional account and subscribe to the online services, which presupposes a SIREN. The number is issued by INSEE when the entity is entered in the Sirene directory after a creation formality on the Guichet des formalités des entreprises (GFE).

In plain English: no SIREN, no secure login that can lodge 2746-SD. Waiting until April of the filing year is how foreign groups miss 15 May.

Who needs to register

According to DGFiP guidance, any TVVI debtor that must lodge the electronic declarations under Articles 990 E and 990 F, and that does not already hold a SIREN, must complete a creation formality on the Guichet unique.

Typical readers of this site include:

a UK Ltd, US LLC, Swiss company or offshore vehicle that owns French property in its own name;
a foreign holding company above a French SCI;
a trust, foundation or comparable institution (each fund or trust in scope usually needs its own registration: absence of legal personality does not remove the duty);
any interposed entity that will file its own 2746-SD for disclosure-based exemption.

You may already have a SIREN if the entity previously registered for other French taxes, employed staff, or opened an establishment. Check Sirene or your Guichet dashboard before starting a duplicate creation.

Entities that historically relied only on a paper or old electronic engagement de communiquer, and never filed 2746-SD, often have no SIREN at all. That group is the highest priority for 2026 setup work.

Why 2027 makes this urgent

Law no. 2026-534 of 25 June 2026 (Article 102) abolishes the standing commitment route for the 2027 campaign (situation as at 1 January 2027). Eligible foreign structures that want disclosure-based exemption must file 2746-SD by 15 May each year. Entities without a French permanent establishment must also designate a French representative under new CGI Article 990 FA.

That combination turns SIREN and e-filing from a "nice to have" into a calendar item. Getting registered, receiving the welcome letter, creating the professional space and activating the TVVI services routinely takes weeks, not an afternoon.

What SIREN and SIRET mean

Identifier	What it is	Why it matters for TVVI
SIREN	Nine-digit number for the legal entity in the Sirene directory	Required to create the professional tax account and to identify the declaring entity on 2746-SD
SIRET	SIREN plus a five-digit establishment NIC (14 digits in total)	Identifies a French establishment if one exists; foreign entities without a PE still need the entity-level SIREN for e-filing

Obtaining a SIREN for TVVI filing does not, by itself, create a French company, open a permanent establishment or put you on corporation tax. It is an identification step so the tax administration can process electronic declarations. Your French tax adviser should still confirm any wider registration consequences for your facts.

How to obtain a SIREN (Guichet unique)

Since 1 January 2023, foreign entities without a French establishment register online on the Guichet des formalités des entreprises: formalites.entreprises.gouv.fr. The old paper EE0 route to the local service des impôts des entreprises (SIE) is no longer processed for this purpose.

High-level path:

Create a declarant account on the Guichet unique.
Start a création d'entreprise formality for the foreign entity.
Complete every field marked with an asterisk (*).
Attach the supporting PDFs listed below.
Sign and submit; the file is routed for validation (foreign entities are typically handled with DGFiP involvement under Guichet rules).
Collect the SIREN on the Guichet dashboard once INSEE has issued it. The competent SIE later sends a welcome letter to the registered seat or correspondence address.

The formality is free according to the TVVI FAQ.

Form tips for TVVI-only foreign entities

DGFiP guidance for entities that are not established in France and are registering mainly for the 3% tax includes:

Identity: foreign legal name, foreign registered office address, foreign registration number if available, and details of the legal representative (individual or company).
Composition / powers: you may add a French tax representative, attorney or accountant with a mandate. If an avocat acts as mandataire, select the appropriate function on the form.
Activity start date: when the entity is liable only for TVVI, use the date of acquisition of the French property (or of the shares/rights that bring the entity into scope).
Activity description: if there is no French trading activity, enter wording such as "Détention d'immeubles et d'autres droits immobiliers" (holding of buildings and other real property rights).
Activity categorisation: for a non-established foreign entity liable only to TVVI, select Activités de services at level 1, then refine levels 2 to 4 as the form requires.
Tax options: answer yes to the question asking whether you are liable to TVVI.
Observations: useful place for an email, phone number and a note that an avocat is acting if relevant. Add a correspondence address if it differs from the foreign seat.

Do not invent a French trading address just to "look local". Accuracy matters more than cosmetics.

Documents foreign entities usually need

For a non-established foreign entity registering for the TVVI teleprocedure, the FAQ lists these attachments (dematerialised PDFs):

Constitutional documents: copy of the articles / constitutive acts, with a French translation of the main elements (legal form, partners, manager, capital, corporate object). A free translation is accepted when the originals are in an EU official language; otherwise a sworn French translation is required.
Home-country extract: copy of the certificate of registration from the foreign commercial (or equivalent) register.
Mandate: if a mandataire or fiscal representative is appointed, a copy of the mandate naming the principal, the validity period and the formalities the agent may perform. French avocats acting in their professional capacity are generally not required to produce an express mandate for this Sirene registration step, under the FAQ's reading of the 1971 lawyers' statute.

Unless the managing office specifically asks again, those documents no longer need to be sent separately to the SIE after Guichet submission.

Build a bilingual pack early: UK or US counsel often underestimates how long certified translations take.

Align the Sirene file with the French title pack

A bilingual notaire can extract the exact owner name from the land registry and SCI documents so the Guichet registration and later 2746-SD match the French deed trail.

Get matched with a bilingual notaire within about 48 hours

Create the professional tax space and activate TVVI services

Once you have the SIREN:

Create an espace professionnel on impots.gouv.fr (simplified or expert mode).
Subscribe to the dedicated services: Déclarer Taxe v. vénale immeuble (declare) and Payer taxe v. vénale immeuble (pay).
Confirm access to the secure messaging service where required (simplified mode usually triggers messaging adhesion automatically).

For millésime year N, the teleprocedure is generally available from 1 January N. The filing and payment deadline remains 15 May (CGI Article 990 F). There is no general extension.

Keep the transmission receipt and a PDF export of the filed return. They are your proof if a notice arrives months later.

Filing 2746-SD: EFI, EDI and payment

Channel	How it works	Practical ceiling
EFI (online form)	You (or your adviser) complete the secure web form and sign electronically	Up to 99 properties and/or 99 interposed entities on the online form
EDI (machine-to-machine)	Filing through an approved EDI partner / software chain	Required once you exceed the EFI ceilings (EDI available since 2023)

Any tax due is paid by télérèglement at the same time. Most well-prepared structures that fully disclose owners above 1% pay nil, but the filing still has to go through.

Full content of the return: Form 2746-SD guide.

Who can click submit: entity or adviser

A French accountant, avocat or specialised firm can create an expert-mode professional space and file for several clients from one portfolio, identifying each entity by SIREN. In that model, the declaring entities themselves are not required to open their own professional spaces for the TVVI filing.

Many foreign groups prefer that route: one French adviser holds the logins, tracks 15 May, and coordinates Article 990 FA representative wording from 2027. Put the mandate in writing and decide who monitors secure messages.

Which tax office handles your file

Management rules in force since 2021 (summarised in the FAQ):

entities with a French seat or French establishment: the SIE for the principal French establishment;
foreign entities without a French establishment that already have a managing SIE for other non-local taxes: that same office;
foreign entities without a French establishment and without another managing SIE: the SIEE of the DINR (Direction des impôts des non-résidents) from the first property held;
certain large groups listed in Annex III to the CGI: Direction des grandes entreprises (DGE).

You generally do not need a special change-of-office formality solely because of the 2021 competence rules. Focus on getting the Guichet registration right and reading the welcome letter carefully.

Working timeline before 15 May 2027

When	Action
Now (2026)	Map every entity that may need 2746-SD. Note whether a SIREN already exists.
+2 to 4 weeks	Assemble articles, register extract and translations; prepare Guichet creation.
After SIREN issued	Open (or instruct your adviser to open) the professional space; subscribe to TVVI declare/pay services.
Q4 2026 / Q1 2027	Agree Article 990 FA representative; freeze 1 January 2027 valuations and shareholder lists above 1%.
By 15 May 2027	File 2746-SD electronically; archive the receipt.
Every year after	Repeat disclosure by 15 May; update Sirene data if the legal representative or address changes.

If you buy in year N, your first TVVI declaration for that holding is usually due by 15 May of year N+1 (situation on 1 January N+1). Use the purchase year to finish SIREN and account setup so you are not improvising in April.

Common delays and mistakes

assuming an old commitment letter removed the need for a SIREN forever (false from 2027 for disclosure-based exemption);
starting Guichet registration in May of the filing year;
registering only the management company when each trust or fund in scope needs its own identifier;
mismatching the French deed name and the Sirene legal name (accents, "Ltd" vs full style, SCI spelling);
forgetting translations or attaching incomplete foreign extracts;
creating the professional space but never adhering to the TVVI declare/pay services;
confusing the TVVI e-filing setup with the accredited fiscal representative used on many non-resident sales.

Where the notaire fits in

A notaire does not normally obtain your SIREN or click the TVVI teleprocedure. Their value for this workflow is upstream and documentary:

confirming who appears as owner on the title and in SCI bylaws;
supplying recent état daté, share registers and deed extracts your Guichet and 2746-SD packs must mirror;
flagging foreign corporate layers at purchase so the compliance calendar starts on day one;
coordinating with your French tax adviser when a sale and a 2746-SD year overlap.

If you still need an office: How to Find an English-Speaking Notaire in France.

Frequently asked questions

Do I need a SIREN to file form 2746-SD?

In practice yes for electronic filing. DGFiP states that access to the teleprocedure requires a professional space, which presupposes a SIREN.

Where do I apply if my company has no French office?

On the Guichet unique (formalites.entreprises.gouv.fr) using a création d'entreprise formality. Since 2023, EE0 filings sent to the SIE are no longer processed for this purpose.

Is registration free?

Yes. The TVVI FAQ confirms the immatriculation formality is free.

Does a SIREN create a permanent establishment in France?

Not by itself. It is an identification number for administrative and tax processing. Ask your tax adviser whether any other French registrations apply to your facts.

Can my French accountant file without our own login?

Yes. An adviser with an expert-mode professional space can file for multiple clients identified by SIREN. Those clients need not each create their own space for that filing.

We signed a commitment years ago and never registered. What now?

Plan SIREN registration and e-filing access in 2026. From the 2027 campaign, disclosure-based exemption requires an actual annual 2746-SD filing by 15 May.

Must every fund or trust obtain its own SIREN?

DGFiP guidance says each fund in scope must file its own 2746-SD or (historically) engagement, and each must register to access the teleprocedure. Managing companies cannot simply file one return covering every fund.

What if I miss 15 May?

After a formal notice you generally have 30 days to regularise. First-time late regularisation has a limited administrative tolerance, available only once. Missing the deadline still risks stress, French correspondence and, if the window closes, the 3% tax itself.

Sources

Speak to a bilingual notaire while your tax adviser opens the SIREN file

Electronic filing only works if the French ownership story is consistent. Start with clear deeds, then register, then declare.

Find a bilingual Notaire within 48 hours · Free matching · In person or video · e.g. Paris or Nice