Section XIX: Social contribution on corporation tax

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Article 235 ter ZC

French General Tax CodeIn force

Updated 8 Nov 2023

I. - Those liable for corporation tax are subject to a social contribution equal to a fraction of this tax calculated on their taxable income at the rates mentioned in I and IV of article 219 and reduced by an allowance which may not exceed 763,000 euros per twelve-month period. Where a financial year or tax period is less than or greater than twelve months, the allowance is adjusted accordingly.

The fraction mentioned in the first paragraph is equal to 3.3% for financial years ending on or after 1 January 2000.

Taxpayers with a turnover of less than 7,630,000 euros are exempt. The turnover to be taken into account is the turnover achieved by the taxpayer during the financial year or tax period, reduced to twelve months where applicable and, for the parent company of a group mentioned in article 223 A or article 223 A bis, the sum of the turnover of each of the companies belonging to this group. At least 75% of the fully paid-up capital of the companies must be continuously held by individuals or by a company meeting the same conditions, at least 75% of whose capital is held by individuals. For the purposes of determining this percentage, the holdings of venture capital companies, venture capital mutual funds, specialised professional funds covered by article L. 214-37 of the Monetary and Financial Code as it read prior to Order no. 2013-676 of 25 July 2013 amending the legal framework for asset management, professional private equity funds, sociétés de libre partenariat, regional development companies and financial innovation companies shall not be taken into account provided that there is no arm's length relationship within the meaning of Article 12 of 39 between the company in question and these latter companies or funds.

II. - For companies 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 et 223 D.

III. (Expired)

III bis - Companies having opted for the regime provided for in II of article 208 C as well as open-ended investment companies with a preponderance of real estate capital mentioned in 3° nonies of Article 208 are not subject to this contribution on capital gains taxed pursuant to IV of Article 219.

IV. - Tax credits of any kind and the claim referred to in Article 220 quinquies are not chargeable against the contribution.

V. - It is assessed and controlled in the same way as corporation tax and under the same guarantees and penalties.

VI. - The terms and conditions for the application of this article shall be laid down by decree.

I.

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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