Section XVII bis: Exceptional corporation tax contribution

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Article 235 ter ZAA

French General Tax CodeIn force

Updated 8 Nov 2023

I. - Corporate income tax payers with sales in excess of €250 million are subject to an exceptional contribution equal to a fraction of this tax calculated on their taxable income, at the rates mentioned in Article 219, for financial years ending on or after 31 December 2011 and until 30 December 2016.

This contribution is equal to 10.7% of the corporation tax due, determined before offsetting tax reductions and credits and tax receivables of any kind.

For taxpayers who are placed under the regime provided for in Article 223 A or Article 223 A bis, the contribution is payable by the parent company. It is based on the corporation tax relating to the overall result and the overall net capital gain defined in articles 223 B, 223 B bis and 223 D, determined before offsetting tax reductions and credits and tax claims of any kind.

The turnover referred to in the first paragraph of this I refers to the turnover achieved by the taxpayer during the financial year or the tax period, reduced to twelve months where applicable, and for the parent company of a group referred to in Article 223 A or Article 223 A bis, the sum of the turnover of each of the member companies of this group.

II. - Tax credits of any kind and the claim referred to in Article 220 quinquies may not be offset against the contribution.

III. - The contribution is assessed, controlled and collected in the same way as corporation tax and subject to the same guarantees and penalties.

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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