VAT on composite supplies: TV subscriptions

The French tax authorities have published this week important clarifications on the VAT rules applicable to subscriptions to television services offered in the form of composite supplies.

What is a composite supply for VAT purposes?

Composite supplies are taxable transactions consisting of several elements which, taken separately, may fall under different VAT regimes and rates.

Depending on whether the elements are independent or closely linked, the supplier must apply either:

• the VAT rates specific to each good and service, or
• a single rate corresponding to the principal supply, extended to its ancillary elements.

Where the principal element cannot be identified, the highest VAT rate among the components applies to the entire supply. Failing this, in the presence of both exempt elements and elements subject to reduced rates, the standard VAT rate (20% in France) applies.

Exception: travel packages offered by tour operators (TOMS regime) are treated as single supplies of services, subject to their own specific rules.

The scope of the operation is assessed from the perspective of the “average consumer,” taking into account the qualitative and quantitative importance of the different elements involved, as well as the overall circumstances of the transaction (Article 257 ter of the French Tax Code).

VAT on TV subscriptions in France

• Linear broadcasting services are subject to the reduced VAT rate of 10%.
• Non-linear services, accessible by the consumer at any chosen moment, are considered as electronic services subject to the standard rate of 20%. This includes subscription video-on-demand (SVOD) services.

The three VAT scenarios for composite TV supplies in France

When a single subscription includes both linear and non-linear services, three taxation scenarios may apply:

1. Application of the reduced 10% rate on linear services and ancillary non-linear services

Examples:

• Replay of a linear broadcast available for up to one month
• Replay of episodes of a series available for no longer than one month after the initial broadcast of the final episode of the season
• Replay of monthly episodes of a series available for a maximum of two months
• Replay of sports competition matches available for no longer than one month after the final match
• Several one-month replays of a film interrupted for at least one month, where the viewing interest becomes negligible from the third month onwards
• Extended replay of news program where viewing interest diminishes rapidly
• SVOD access to content linked to linear broadcasts (e.g. actor interviews)
• SVOD access to content of negligible economic value to the consumer
• Multi-screen viewing or recording of linear broadcast programs

2. Application of separate VAT rates where services are independent

Typically applies to a TV subscription with an optional SVOD add-on.

• Linear services → 10%
• SVOD services → 20%
• Digital books included → 5.5%

3. Application of the highest VAT rate where services are not dissociable

Where it is not possible to determine the principal or predominant element among closely linked services, the entire subscription is subject to the highest applicable rate.

Example: a single-price subscription including both TV channels (10%) and SVOD services (20%), or a catalogue of e-books (5.5%). In such cases, the overall subscription will be taxed at 20% or, where relevant, 10%.

Conclusion

Following the comments published on 14 May 2025 concerning composite supplies, the new clarifications issued in BOFiP on 3 September 2025 provide significant guidance on the VAT treatment of complex television service packages.

All operators offering packages composed of multiple services and/or goods must take these guidelines into account—based on national and EU case law—in order to properly identify the scope of their economic activities and the applicable VAT regime.

For operational support, please contact our VAT experts: contact@btobnice.com

Related article: VAT on television services – comments of the French Council of State on complex supplies