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Running a business across the UK, France and Germany: one accounting stack for three tax systems

Operating in the UK, France and Germany means three VAT systems, three payroll frameworks and two currencies. Most tools solve one country. Here's how a unified approach works β€” and what to watch for.

S
Sophie LaurentΒ· Customer Success
28 May 20269 min read

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The compliance landscape by country

### United Kingdom - VAT: Making Tax Digital β€” quarterly returns submitted via MTD API to HMRC - Income Tax: MTD ITSA β€” quarterly submissions for sole traders and landlords from April 2026 - Corporation Tax: CT600 + iXBRL accounts to Companies House - Payroll: Real Time Information (RTI) to HMRC every pay period; CIS300 monthly for construction businesses

### France - TVA: CA3 declaration monthly or quarterly to DGFiP; Chorus Pro for public sector buyers; Factur-X mandatory from 2026 - Payroll: DSN (DΓ©claration Sociale Nominative) monthly to URSSAF - Annual accounts: Liasse Fiscale (Cerfa 2050–2059) via DGFiP

### Germany - UStVA: Advance VAT return monthly or quarterly via ELSTER/ERiC - E-invoicing: ZUGFeRD / XRechnung β€” mandatory receipt from 2025, mandatory issuance from 2027 - Payroll: DATEV-compatible payroll for Steuerberater; social contributions to Sozialversicherung - Annual accounts: Jahresabschluss filed with the Bundesanzeiger (GmbH/AG)

The multi-currency problem

Most UK/FR/DE businesses invoice in both GBP and EUR. This creates:

  • **Realised FX gains/losses** β€” when a EUR invoice settles at a different rate than when it was raised
  • **Unrealised FX exposure** β€” outstanding EUR receivables valued at the period's spot rate
  • **Reporting** β€” UK entities report in GBP; FR and DE in EUR; consolidations need currency translation

Finovo records every invoice and payment in both the transaction currency and the workspace's base currency, computes FX differences automatically, and posts them to the correct FX gain/loss account.

One subscription, three countries

Rather than running separate Xero (UK), Pennylane (FR) and Lexoffice (DE) instances:

  • **UK workspace:** MTD VAT, MTD ITSA, CIS, BrightPay sync, GBP/EUR
  • **FR workspace:** TVA/CA3 DGFiP, Chorus Pro e-invoicing, Factur-X, EUR
  • **DE workspace:** UStVA ELSTER, ZUGFeRD/XRechnung, DATEV export, GoBD archiving, EUR

Your chart of accounts, contacts, and products are shared. Tax configurations are per workspace. Reports can be pulled per entity or consolidated across all three.

What a local accountant still handles

Finovo manages the compliance mechanics β€” but not tax strategy or complex year-end work. You'll still want:

  • A UK accountant for CT600, R&D claims, and Companies House filings
  • A French expert-comptable for Liasse Fiscale and URSSAF queries
  • A German Steuerberater for Jahresabschluss and Bundesanzeiger filing

Finovo's accountant access feature lets you invite all three with appropriate permissions β€” they work from a shared source of truth, export in the format their tools expect (DATEV for DE, FEC for FR), and you avoid the spreadsheet-by-email cycle.

The biggest risk: treating each country as independent

The most common mistake is running each country's books in a silo and attempting to consolidate at year end. FX differences accumulate untracked, intercompany balances drift, and VAT returns in one country reference transactions that were posted differently in another.

Start with unified accounting from day one β€” even if you operate in only one country today. Expansion is far less painful when the chart of accounts, currencies, and contact records are already consistent.

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