Call Us + 33 1 84 88 31 00

Article 223 quinquies A of the French General Tax Code

The legal persons designated in 2 of Article 218 A may be invited, by the tax department, to designate within ninety days of receipt of this request, a representative in France authorised to receive communications relating to the assessment, collection and litigation of tax (1). However, the obligation to appoint a tax representative does not apply to persons who have their registered office in another Member State of the European…

Read More »

Article 223 quinquies B of the French General Tax Code

I. – Legal entities established in France: 1° Whose annual turnover excluding tax or gross assets shown on the balance sheet is greater than or equal to 50 million euros; 2° Or holding at the close of the financial year, directly or indirectly, more than half of the capital or voting rights of a legal entity (legal person, body, trust or comparable institution established or set up in France or…

Read More »

Article 223 quinquies C of the French General Tax Code

I. – 1. A declaration including a country-by-country breakdown of the group’s profits and economic, accounting and tax aggregates, as well as information on the location and activity of the entities making it up, the content of which shall be set by decree, shall be submitted in dematerialised form, within twelve months of the end of the financial year, by legal entities established in France that meet the following criteria:…

Read More »

Article 223 A of the French General Tax Code

I. – A company, hereinafter referred to as the “parent company”, may be solely liable for the corporation tax due on all the profits of the group formed by itself and the companies in which it holds at least 95% of the capital on a continuous basis during the financial year, directly or indirectly through companies or permanent establishments that are members of the group, hereinafter referred to as the…

Read More »

Article 223 A bis of the French General Tax Code

I. – By way of exception to the first sentence of the first paragraph of I of Article 223 A, when a public industrial and commercial establishment subject to corporation tax under ordinary law draws up consolidated accounts under the conditions provided for in the first paragraph of l’article L. 233-18 of the French Commercial Code, it may be solely liable for the corporation tax due on all the profits…

Read More »

Article 223 B of the French General Tax Code

The overall result is determined by the parent company by making the algebraic sum of the results of each of the companies in the group, determined under the conditions of ordinary law or in accordance with the procedures set out in article 214. Participation income received by a group company from a company that has been a member of the group for more than one financial year and participation income…

Read More »

Article 223 B bis of the French General Tax Code

I. – The net financial charges borne by the group are deductible from the overall result, up to the higher of the following two amounts: 1° Three million euros; 2° 30% of the group’s result determined under the conditions of II. The amount of three million euros mentioned in 1° of this I refers to one financial year, if necessary reduced to twelve months. II. – The result referred to…

Read More »

Article 223 C of the French General Tax Code

The overall profit is taxed in accordance with the procedures set out in the second paragraph of paragraph I of Article 219. The overall net profit obtained pursuant to article 223 H, when the option for the regime provided for in article 238 is exercised, is subtracted from the overall profit to be taxed separately in accordance with the procedures provided for in the second paragraph of a of I…

Read More »

Article 223 D of the French General Tax Code

The overall net long-term capital gain or loss is determined by the parent company by making the algebraic sum of the net long-term capital gains or losses of each of the companies in the group, determined and taxable in accordance with the procedures set out in articles 39 duodecies to 39 quindecies. The provisions of article 39 quindecies are applicable to the overall net long-term capital gain and loss. The…

Read More »

Contact a French lawyer now

Contact a French Business Lawyer

Our French business lawyers are here to help.
We offer a FREE evaluation of your case.
Call us at +33 (0) 1 84 88 31 00 or send us an email.

Useful links

You have a question in French Business Law?

Our French business lawyers are here to help.
We offer a FREE evaluation of your case.
Call +33 (0) 1 84 88 31 00 or send us an email.

All information exchanged through this website will be communicated to lawyers registered with a French Bar and will remain confidential.