The French government presented its draft Finance Law for 2020. It includes amendments regarding the scheduled reduction on corporate tax rates, which began in 2018 but was partially reversed for large companies for 2019.
Under the draft finance law, the government proposed the corporate income tax reduction path for companies with an annual turnover of EUR250 million or higher is proposed as follows:
The Bill also includes the transposition of the measures to combat hybrid mismatch arrangements provided for in Articles 9, 9a and 9b of European Union Anti-Tax Avoidance Directive (EU) 2016/1164 (2016) (ATAD 1), as amended by the COUNCIL DIRECTIVE (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (ATAD 2).
In particular, four categories of hybrid mismatches are covered by the Bill:
Other than the aforementioned points, the government also proposed the amendment of dividend withholding tax rules. The new rules to allow for a refund of dividend withholding tax for non-resident loss-making companies. Such amendment was made in order to comply with a 22 November 2018 judgment of the Court of Justice of the European Union, which found that the effective dividend tax exemption for loss-making resident companies, but not for loss-making non-resident companies, constituted a restriction on the free movement of capital in violation of EU law.
In addition, it is worth noting that Article 55 of the Bill proposes the sanctionatory publication of a list of non-cooperative digital platforms. This list was laid out to support French unilateral proposal to impose Digital Service Tax.
Source: French Government