Corporate income tax of multinational groups: French taxable profit based on the share of turnover achieved in France
The amendment creates Article 209-0 A bis of the General Tax Code: for companies belonging to a group with total turnover above €100 million whose parent is domiciled outside France, taxable profit in France would equal the group's overall profit multiplied by the share of turnover achieved in France. A single group company would be liable for the tax due in France; groups would report, for each State, their locations, turnover and pre-tax profit, failing which they would be barred from operating in France. Entry into force on 1 January 2027; the Government would report on the tax treaties to renegotiate.
Measure originators
No official estimate found for this measure.
Measure impact
Multinational groups with turnover above €100 million and a foreign parent would be taxed in France on a share of their worldwide profit proportional to their French turnover. Adopted by 74 votes to 72 against the opinion of the finance committee; the general rapporteur raised a risk of conflict with tax treaties (Article 55 of the Constitution).
Official references
Sources
Procedure timeline
Follow the progress of this fiscal measure through the different stages of the parliamentary procedure.
Debate and vote
Débat et vote en séance publique à l'Assemblée nationale, ou engagement de la responsabilité du Gouvernement (article 49.3)
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