I: Taxable profits and income

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Article 238 bis-0 A

French General Tax CodeIn force

Updated 8 Nov 2023

Companies subject to corporation tax on the basis of their actual profits may benefit from a tax reduction equal to 90% of payments made towards the purchase of cultural property having the status of national treasures that has been refused an export certificate by the administrative authority, under the conditions set out in

article L. 111-4

of the French Heritage Code and for which the State has made the owner of the property an offer to purchase in accordance with the conditions set out in

article L. 121-1

of the same code.

This tax reduction is also applicable, after a reasoned opinion from the commission provided for in the aforementioned article L. 111-4, to payments made towards the purchase of cultural property located in France or abroad, the acquisition of which would be of major interest to the national heritage from the point of view of history, art or archaeology.

Payments are not deductible when determining taxable profit.

Payments must be approved by the ministers responsible for culture and the budget.

The tax reduction applies to corporation tax due in respect of the financial year during which the payments are accepted. However, the tax reduction may not exceed 50% of the amount of tax due by the company in respect of that financial year in accordance with I of

Article 219

. For companies that are members of a group within the meaning of

Article 223 A or Article 223 A bis

, the 50% limit applies for the group as a whole by reference to the tax payable by the parent company of the group.

A decree in the Conseil d'Etat sets out the terms and conditions for the application of this article.

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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