France introduces a 15% minimum tax rate for multinationals groups
Philippe PESCAYRE
The French Finance Law for 2024, presented on 4 October 2023, includes the introduction of a “minimum level of taxation set at 15% for the profits of groups of multinational companies with a base in France, as well as major national groups that develop their activities solely on French territory”.
This provision transposes into French law a directive dated 12 December 2022, which has its origins in the OECD’s publication on 8 November 2019 of a “global proposal to combat tax base erosion”, commonly referred to as “GloBE” (for “Global Anti-Base Erosion”).
This minimum tax will apply from 2026 to multinationals with consolidated sales of €750 million or more in at least two of the four financial years preceding the financial year in question.
In practice, if a State refuses to introduce an effective minimum tax of 15% and applies a lower rate, France will tax the difference on profits located in that State. The minimum tax will be assessed on a taxable basis different from the one used for the computation of corporate income tax.