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Generic Tax Name Corporate income tax - Minimum annual corporation tax
Tax name in the national language Imposition forfaitaire annuelle des sociétés
Tax name in English Minimum annual corporation tax
Member State FR-France
Tax in force since 1974/01/01
If abolished, date on which the tax ceases to apply 2014/01/01
Business version date 2015/01/01
Version date 2015/03/24
This file was last updated on

Type of tax
Direct taxes Personal income tax
Corporate income tax
Other

Indirect taxes VAT
Excise duty (EU harmonised)
Alcoholic beverages
Energy products and electricity
Manufactured tobacco
Other

Social security contribution Employers
Employees
Other
 
Legal base

Articles 223 septies to 223 undecies of the General Tax Code (Code général des impôts).

 
Who sets
The tax rate is set by




The tax base is set by




The reliefs are set by




Comments
 
Beneficiary





Comments

 
Geographical Scope
 
Taxpayers
Domestic-source income of non-resident entities is Taxed
Not Taxed
Comments
 
Tax object and basis of assessment
As general rule, taxable income under corporate income tax includes also








Comments

Income considered Domestic income
Worldwide income (subject to double-tax relief)
Comments

Comments

The minimum annual corporation tax was levied according to the turnover plus financial income, for the last complete fiscal year.

 
Deductions, Allowances, Credits, Exemptions
Valuation of inventory
System First-in first-out (FIFO)
Last-in first-out (LIFO)
Average cost
Specific identification (unit method)

Comments

Depreciation rules
 
Buildings
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate
 
Movable (tangible) assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate
 
Movable fixed assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate
 
Intangible assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate
 
Land (if any)
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate


Comments

Are there limits to interest deductions? Yes No
If yes:
Definition of deduction limit

Comments

Is there an Allowance for Corporate Equity? Yes No
If yes:
Notional rate applied for allowance

Comments

Losses
Loss carry-forward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 

Comments


Comments

Exemptions:

-Non-profit institutions as defined in article 206 of the General Tax Code (Code général des impôts);

-Companies exempt from corporation tax under articles 207, 208 and 208D of the General Tax Code;

-Legal persons whose purpose is to provide their members with free use of properties;

-Companies entitled to corporation tax exemption as applied to new businesses;

-Licensed management centres or associations;

-Associations with the activity of enhancing local social life;

-Employer groups operating in the conditions set out in articles L 127-1 to L 127-9 of the Employment Code (Code du travail).

 

Deductibility:

The minimum amount was deductible like other costs without a limit of time.

 
Rate(s) Structure
Nominal corporate income tax rate Rate:

Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate: 0.00 %


Comments

Fixed levy, depending on gross business revenue :

under € 15 million : € 0

between € 15 million and € 75 million : € 20,500

between € 75 million and € 500 million : € 32,750

over € 500 million : € 110,000


Special tax rate for SMEs
Special tax rates apply to SMEs: Yes No
If yes:
Nominal corporate income tax rate Rate:
Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate:


Comments
 
International aspects
Treaty countries Non-treaty countries
 
Repatriated profits are taxed according to the following system Exemption system Exemption system
Tax credit Tax credit
Deduction Deduction
 
Interest received is taxed Yes No Yes No
Tax rate on interest received
Outgoing dividends withholding tax
Outgoing interest payments withholding tax
 
Foreign losses can be set-off Yes No Yes No
If yes:
Minimum direct or indirect shareholding to qualify loss-offset (if applicable)
 
Loss carry-forward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Controlled foreign company (CFC-)rules exist? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Threshold for capital or voting power held directly or indirectly by resident in non-resident company
CFC-rules apply if foreign tax rate is lower than
CFC-rules apply for passive income only? Yes No Yes No

Comments   Treaty countries

Comments   Non-treaty countries
 
Measures against profit shifting
 
Do Thin Capitalization (TC) rules exist? Yes No
If yes:
Date of first introduction
Introduced as Explicit TC law
Part of CIT law
Test for TC Ratio
Arm's length
If ratio
Value of numerical ratio:
Definition numerator
Definition denominator
 
Debt considered for test Internal
Internal and external
TC depends on shareholding? Yes No
Substantial shareholding threshold
 
Type of shareholding Direct
Indirect
Automatic remedy Yes No
Remedy Non-deductibility of interest
Reclassification as dividend
 
Rules apply to All companies
Foreign companies
Non-EU companies
Transfer pricing rules exists? Yes No
If yes:
Arm’s length principle applied? Yes No
 
Remedy Fee
Tax base increase
 
Tax due date

The minimum annual corporation tax had to be paid by latest 15th March.

 
Tax collector

The minimum annual corporation tax had to be paid to the Public Finances Directorate General's accountant (comptable de la Direction Générale des Finances Publiques).

 
Special features

French companies of which 95% of the capital is held directly or indirectly by another French company and which are subject to the special treatment laid down in article 223A of the General Tax Code (Code général des impôts) - taxation of the parent company on all the results of the group - awere subject to minimum corporation tax. This was to be paid, on their behalf, by the parent company.

The suppression of this tax is effective from 2014. 

 
Economic function







Comments

 
Environmental taxes



Comments
 
Tax revenue
ESA95 code D51OE

Year
Annual tax revenue (millions)
Currency
Tax revenue as % of GDP
Tax revenue as % of total tax revenue
2012 EUR
2011 EUR
2010 EUR
2009 EUR
2008 1,720.00 EUR 0.09
2007 1,656.00 EUR 0.09
2006 1,633.00 EUR 0.09
2005 1,817.00 EUR 0.10
2004 1,807.00 EUR 0.11
2003 1,668.00 EUR 0.10
2002 1,680.00 EUR 0.10
2001 1,562.00 EUR 0.10
2000 1,484.00 EUR 0.10

Comments