Details

  • Service: Tax, International Corporate Tax, Global Indirect Tax, Mergers & Acquisitions, International Executive Services
  • Type: Regulatory update
  • Date: 1/17/2012

France - Summaries of new corporate tax measures effective in 2012, and of certain other tax measures enacted in 2011 

January 17:   New tax measures, enacted in late December 2011, include the following provisions as relating to corporate taxpayers:
  • The introduction of a corporate income tax surcharge at a rate of 5% for large corporate taxpayers
  • A change in the method of computing tax losses for employee profit sharing purposes
  • A limitation on the deduction of interest expenses relating to the acquisition of qualifying participations (titres de participation)
  • New measures concerning the disposal of qualifying participations between related companies
  • Rules on the reinforcement of the existing anti-abuse provision in case of licensing or sub-licensing of qualifying industrial property between related companies
  • New transfer tax rates on disposals of shares in non-real estate companies
  • Changes to the computation of the transfer tax liability on the disposal of shares in real estate companies
  • Increased withholding tax rates on dividend and other securities income paid to non-residents
  • A new, second category of “reduced VAT rate” at 7%

Other tax measures enacted in 2011 include:


  • The introduction of a minimum tax mechanism (i.e., rules restricting NOL carryforwards and carrybacks)
  • New rules on the capital gains taxation of qualifying participations
  • A value-added sharing bonus regime

To read a January 2012 report prepared by FIDAL (a French law firm that is independent from KPMG and its member firms) : France: Summaries of new corporate tax measures effective in 2012, and of certain other tax measures enacted in 2011




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