Section I: General information

It is established a tax on all profits or income made by companies and other legal entities designated in article 206. This tax is referred to as corporation tax.

For the assessment of corporation tax, no account shall be taken of a scheme or series of schemes which, having been put in place to obtain, as a principal objective or as one of the principal objectives, a tax advantage which runs counter to the object or purpose of the applicable tax law, are not genuine having regard to all the relevant facts and circumstances. A scheme may comprise several…

I.-For the purposes of this article and articles 205 C and 205 D, the following definitions shall apply: 1° Hybrid arrangement: a situation in which: a) A payment is made under a financial instrument in respect of which a) A payment made in respect of a financial instrument gives rise to a deductible expense in the State of residence of the debtor without being included in the taxable income in…

When a hybrid entity of a reverse hybrid scheme is incorporated or established in France, its income shall be taxed, as the case may be, either under corporation tax or under the conditions provided for in Article 8 of this Code, insofar as it is not taxed in another State. The first paragraph of this article shall not apply to undertakings for collective investment, such an undertaking being defined as…

When payments, expenses or losses deductible from the taxable income of a taxpayer who is resident in France and in another State pursuant to the rules of that State are taken into account in both States, their deduction is not allowed in France. However, this deduction is allowed in France when: 1° The payment, expense or loss likely to be the subject of a double deduction is included in the…