I: Income tax deducted at source

Articles in this section · 6

Article 187

French General Tax CodeIn force

Updated 8 Nov 2023

1. Subject to the provisions of 2, the rate of withholding tax provided for in article 119 bis is set at:

1° For beneficiaries who are legal persons or organisations, regardless of their form:

- 17% for interest on negotiable bonds; however, this rate is set at 15% for income referred to in 1° of article 118 and relating to securities issued on or after 1 January 1965 as well as for redemption lots and premiums referred to in 2° of article 118 and relating to securities issued on or after 1 January 1986;

The rate provided for in 2° of l'article 219 bis, for dividends that benefit bodies that have their registered office in a Member State of the European Union or in another State party to the Agreement on the European Economic Area that has entered into an administrative assistance agreement with France to combat tax evasion and avoidance and that would be taxed under the conditions provided for in 5 of Article 206 if they had their registered office in France;

- That provided for in the second paragraph of I of Article 219 for all other income.

2° 12.8% for individual beneficiaries.

2. The rate of the withholding tax provided for in 2 of article 119 bis is set at 75% for the products mentioned in articles 108 to 117 bis and paid outside France, in a non-cooperative State or territory within the meaning of article 238-0 A other than those mentioned in 2° of 2 bis of the same article 238-0 A, unless the debtor provides proof that the distributions of these products in this State or territory have neither the purpose nor the effect of allowing, for tax evasion purposes, their localisation in such a State or territory.

Mariela Petrova

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Common Questions

Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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