Exceptional contribution on corporate income tax for large corporations (art.11)
Companies with sales in France of €1 billion or more would be subject to an exceptional and temporary contribution, payable for the two consecutive financial years ending on or after December 31, 2024. The same rule would apply to corporate tax groups, in which case the group turnover would be calculated by adding together the sales of all the companies in the group. The contribution would then be payable by the parent company. Tax reductions and credits, as well as tax claims of any kind, would not be offset against the exceptional contribution, which would not be deductible from taxable income. The contribution would be proportional to the amount of corporate income tax due and its rate would depend on the turnover amount:
- For taxpayers with sales greater than or equal to €1 billion and less than €3 billion, the contribution rate would be 20.6% for the first financial year ending on or after December 31, 2024, and 10.3% for the second financial year ending on or after the same date.
- For taxpayers with sales of €3 billion or more, the contribution rate would be 41.2% for the first financial year ending on or after December 31, 2024, and 20.6% for the second financial year ending on or after the same date.
Lastly, the contribution would be paid spontaneously to the competent public accountant, no later than the payment of the corporate income tax settlement balance. No advance payments would have to be made.
Tax on capital reduction by cancellation of shares resulting from a company's repurchase of its own shares (art. 26)
Companies headquartered in France with individual or consolidated sales (excluding tax) in excess of one billion euros in the last financial year would be subject to a tax on capital reductions resulting from the cancellation of shares following certain share buybacks.
For the purposes of this rule, sales would be assessed at the level of the consolidated group as defined by the French Commercial Code. This calculation method differs from that used for the purposes of the exceptional corporate income tax contribution for large companies.
Only capital reductions carried out on or after October 10, 2024 would be covered.
Capital reductions carried out with a view to allocating shares to certain categories of persons, or for the purpose of facilitating a merger or demerger by buying back and cancelling shares representing no more than 0.25% of the amount of the share capital, would be excluded from the scope of that tax.
The tax would be based on the amount of the capital reduction and a fraction of the sums which, for accounting purposes, have the character of capital-linked premiums.
The tax rate would be 8% and would not be deductible.
Exceptional contribution on the operating income of major shipping companies (art.12)
Companies benefiting from the flat-rate tax regime for shipping companies set out in article 209-0 B of the CGI (tonnage-based taxation) and with sales of €1 billion or more would be liable for an exceptional contribution for the two consecutive financial yearsending on or after December 31, 2024. In the case of integrated groups, the tax would be payable by each company that individually meets the aforementioned sales condition.
The tax base would be equal to the operating income for the portion corresponding to the operations for which the option for the favourable tonnage tax regime has been exercised. The tax rate would be set at 9% for the first financial year ending on or after December 31, 2024, and at 5.5% for the second financial year ending on or after the same date. As with the exceptional corporate income tax, tax reductions and credits, as well as tax receivables of any kind, would not be deducted from the exceptional tax, nor would it be deductible from taxable income.
It would be paid spontaneously to the relevant public accountant no later than the payment of the corporate income tax settlement balance.
