With this action, the law will be enacted very soon.
Summary of certain corporate tax changes
The new law introduces an additional 3% tax on dividend distributions or on sums treated in the same way for tax purposes. The intent of this 3% tax is to finance the repeal of a withholding tax on dividends distributed by French companies to foreign UCITS (undertaking for collective investment in transferable securities), pursuant to the 2012 judgment of the Court of Justice of the European Union in the Santander case.
The 3% tax is payable by French and foreign companies that are subject to corporate income tax in France, with certain exceptions.
The new law also provides that capital loss triggered by the transfer of shares during a period that is less than two years after their issuance is no longer deductible (up to the difference between the book value and the fair market value of the shares) if the fair market value is lower than the book value. This provision is to apply to the transfer of shares received in return for a contribution made as from 19 July 2012.
The new law contains a measure providing for a “special contribution” to be paid on 30 September 2012, in an amount equal to the amount of systemic risk tax that was paid on 30 April 2012. Also, for subsequent years, the rate of the systemic risk tax is increased from 0.25% to 0.5%.
Also, the new law increases the rate of the financial transaction tax to 0.2% from 0.1%.
Read an August 2012 report [PDF 160 KB] prepared by STC Partners* in France: Second Amended Finance Law for 2012
*STC Partners is a French law sublicensee of KPMG International in tax.