Corporation tax

Taxable operations

You must report the corresponding profits and pay corporation tax in France, and the contribution on any rental income:

  • If you operate as a property dealer in France
  • If you are a company with foreign capital owning an interest in a French company (property holding company (SCI), economic interest group (EIG), joint venture, general partnership (SNC), etc.)
  • If you rent property in France either yourself, through a company or through a property holding company

Article 218 A(2) of the French General Tax Code provides that legal entities which do not have their registered office in France but which carry on operations or own assets there, are taxable in the place set by an order from the Minister for the Economy and Finance.

Article 23 ter of Appendix IV to the French General Tax Code stipulates that the place of taxation for companies and legal entities, which do not have their registered office in France but which carry on operations or own assets there, is:

  • The location of the main place of business for companies or legal entities whose operations in France are carried on in one or more establishments
  • The Foreign Business Tax Department for companies or legal entities that usually carry on an independent profession or commercial operations in France without having an establishment there 
  • The location of the property for companies or legal entities that only carry on a property-based activity in France and have real property there which is either rented out or not

If there are several places of taxation once this rule has been applied, taxation of all the relevant real property shall be assessed by the Foreign Business Tax Department.

Tax obligations

All companies must file their earnings declaration online.

The declaration (return no. 2065-SD), together with its appendices, must be filed:

  • Either on the 2nd business day following 1 May if the financial year is the same as the calendar year
  • Or within three months of the financial year-end if this is not 31 December

Corporation tax must be spontaneously computed and paid. Payment is staggered over the year and is made using instalment (form no. 2571-SD) and balance (form no. 2572-SD) statements that are filed electronically.

Relevant department

For corporation tax, the following companies come under the remit of the Foreign Business Tax Department:
Companies with foreign capital that are not established in France and that are taxable on the proportion of earnings derived from their interest in a French partnership that has not opted for corporation tax (property holding company, economic interest group, general partnership, joint venture).

  • Foreign companies not established in France that own at least two properties there and are managed by different departments, for income derived from these properties
  • Foreign companies not established in France that carry on a property dealer business

Individuals who reside abroad and who carry on a property dealer business in France are managed by the Foreign Business Tax Department.

Non-professional renters of furnished accommodation who reside abroad are not managed by the Foreign Business Tax Department. VAT returns and business profit declarations are filed with the Business Tax Department in the location of the furnished accommodation or, if the renters own several furnished accommodation units managed by different departments, in the location of the furnished accommodation unit that generates the most income.
 

Contact details of the relevant department

You must register with:

Service des impôts des entreprises étrangères (SIEE)
10, rue du Centre
TSA 20011
93465 Noisy-le-Grand Cedex

For further informations, please contact: + 33 (0)1 72 95 20 31
 

MAJ DINR-PRO le 31/01/2019