France

A resident company is subject to CIT in France on its French-source income. In that respect, income attributable to foreign business activity (if there is no treaty in force between France and the relevant foreign country) or to a foreign PE (if a tax treaty applies) is excluded from the French tax basis.

A non-resident company is subject to CIT in France on income attributable to French business activity or to a French PE, as well as on income from real estate located in France.

France levies CIT as follows:

* Situation of small corporations not addressed.

** Only concern corporations having revenue in excess of EUR 250 million.

For FY opened as of January 1, 2021, the reduced CIT rate of 15% that applies for small corporations on their first EUR 38,120 of taxable profits (according to the French tax Law definition) is extended to the corporations realising a turnover up to EUR 10 million (compared to EUR 7,63 million for FY opened before January 1, 2021).

Social contribution tax

The social contribution tax is due by any corporation at the rate of 0.16% assessed on the revenue excluding VAT and after deduction of a EUR 19 million relief.

Patent box regime

Under certain conditions, income derived from the sale or license of patents or patentable inventions, as well as software under restrictive conditions, is taxed at a reduced CIT.

Capital gains

A reduced tax rate applies to certain capital gains. See Capital gains in the Income determination section for more information.

Local income taxes

No income tax is levied on income at the regional or local level.