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France’s 2025 Finance Law has finally been passed, introducing a series of transformative tax measures for large corporations and high-income taxpayers. Here’s what you need to know to navigate these changes successfully:
Corporate Taxation: A New Era
Exceptional Corporate Surtax
- Companies with revenues over EUR 1 billion now face an additional corporate income tax surcharge, with rates varying from 20.6% to 41.2% depending on your business size.
CVAE Adjustment
- The abolition of the Contribution on Companies’ Added Value (CVAE) has been delayed to 2030, with annual rate adjustments. For 2025, expect rates to align with those from 2024, plus a supplementary contribution to balance out the fiscal impact.
Share Buy-Back Tax
- A new 8% tax targets capital reductions from share buy-backs for companies with sales exceeding EUR 1 billion, impacting corporate financial strategies.
Dividend Withholding Tax
- New beneficial ownership rules for dividend payments aim to close loopholes in tax evasion schemes.
Financial Transaction Tax Increase
- The tax rate has been upped from 0.3% to 0.4%, influencing investment decisions.
High-Income Individuals: What’s Changed?
Minimum Tax on High-Income Earners
- A temporary 20% minimum effective tax rate has been introduced for individuals with incomes above EUR 250,000 (or EUR 500,000 for joint filers), ensuring a baseline tax contribution.
Management Packages Tax
- Gains from management packages are now split into salary income and capital gains, based on a performance cap, offering new tax planning considerations.
International Tax Compliance
GloBE Rules and OECD Guidance
- France updates its tax laws to be in sync with OECD’s latest guidance on global minimum taxation, affecting how multinational companies manage their tax liabilities.
DAC 8 Crypto Asset Reporting
- Starting from 2026, crypto asset service providers must report transactions, enhancing transparency in the digital asset space.
Actionable Takeaways
- For Corporations: Review your fiscal strategy to adapt to the new surtaxes, tax on share buy-backs, and international tax compliance.
- For Individuals: High earners should calculate their effective tax rate and consider the implications of managing their financial packages under new tax rules.
You might also want to know about France’s Excise Tax Refunds Go Digital
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