III: Capping of certain income tax benefits

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200-0 A

Article 200-0 A

French General Tax CodeIn force
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Updated 8 Nov 2023

1. The total tax benefits mentioned in 2, with the exception of those mentioned in articles 199 undecies A, 199 undecies B, 199 undecies C and 199 unvicies and in XII of Article 199 novovicies, may not provide a reduction in tax due of more than an amount of €10,000.

The total of the advantages mentioned in the first paragraph of this 1, retained within the limit of €10,000, increased by the amount of those mentioned in Articles 199 undecies A, 199 undecies B, 199 undecies C and 199 unvicies and in XII of Article 199 novovicies, cannot provide a reduction in the tax due greater than the sum of an amount of €18,000.

2. The tax benefits used to apply the ceiling mentioned in 1, in respect of a tax year, are as follows:

a) The tax benefit provided by the depreciation deductions provided for in h and l of 1° of I of article 31 and to l'article 31 bis ;

b) Reductions, including, where applicable, for their amount acquired in respect of a previous year and carried forward, and income tax credits, with the exception of those mentioned in articles 199 quater B, 199 quater C, 199 quater F, 199 septies, 199 terdecies-0 B, 199 quindecies, 199 octodecies, 199 vicies A, 199 tervicies, 200,200 bis, 200 quater A, 200 decies A, 200 undecies, 238 bis and at 2 to 4 of I of Article 197, the tax credits mentioned in 1° of II of Section 5 of Chapter I of this Title, and the tax credit corresponding to tax withheld at source abroad or the discount in lieu thereof, as provided for by international agreements.

3. The tax reduction acquired in respect of the investments mentioned in the first sentence of the twenty-sixth and twenty-seventh paragraphs of I of Article 199 undecies B is retained for the application of the ceiling mentioned in the second paragraph of 1 for 34% of its amount. The tax reduction acquired in respect of the investments mentioned in the second sentence of the twenty-sixth paragraph of I of article 199 undecies B is retained for the application of the ceiling mentioned in the second paragraph of 1 for 44% of its amount. The tax reduction acquired in respect of the investments mentioned in Article 199 undecies C is retained for the application of the ceiling mentioned in the second paragraph of 1 for 30% of its amount.

4. A decree sets out the terms and conditions for the application of this article.

Mariela Petrova

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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.

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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.

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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

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15+ Years In Corporate Practice

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