'Carrez amendment': add-back of financial expenses on equity holdings not managed from France
The fourth amending finance law for 2011 requires companies subject to corporate tax to add back to their taxable profit a flat-rate share of their financial expenses when they cannot show that decisions on the equity holdings acquired are taken in France, by themselves or by a group company established in France. The add-back applies for the year of the test and until the eighth year after the acquisition.
Measure originators
No official estimate found for this measure.
Measure impact
Affects companies holding at least €1 million of equity holdings and financing acquisitions through debt, notably French subsidiaries of foreign groups. Exclusions apply if the acquisition is not debt-financed or if the group's debt ratio is equal to or higher than the company's. Applies to financial years starting from 1 January 2012; replaced in 2019 by the limitation on interest deductibility under the ATAD directive.
Official references
Sources
Procedure timeline
Follow the progress of this fiscal measure through the different stages of the parliamentary procedure.
Administrative implementation
Entrée en vigueur de la mesure et mise en œuvre par l'administration
Possible referral to Constitutional Council
Décision de conformité / censure partielle
President of the Republic signature
Publication au Journal officiel
National Assembly has the final say
Si échec CMP
Debate and vote
Debate and vote
Débat et vote en séance publique à l'Assemblée nationale, ou engagement de la responsabilité du Gouvernement (article 49.3)
Council of Ministers
Validation interne