On 2 November 2017, the French government announced details of proposed “exceptional surcharges” which will be 15% and will be imposed on corporate income tax due by companies with gross revenue exceeding EUR 1 billion for financial years ending between 31 December 2017 and 30 December 2018.

Taxpayers with revenue exceeding €3 billion would be subject to an “additional contribution” equal to 15% of their corporate tax liability, again before taking into consideration any offsets of tax credits or tax reductions. In other words, these taxpayers would be subject to a total surcharge of 30% of their gross corporate tax liability.

With the addition of the surcharges(taking into account the 3.3% existing surcharge that would be expected to apply to most of these taxpayers), the overall maximum rate of corporate tax for the financial years closed between 31 December 2017 and 30 December 2018 will be as follows:

• 39.43% for taxpayers subject only to the “exceptional contribution”
• 44.43% for taxpayers subject to both “exceptional” and “additional contributions”

Tax credits or reductions as well as tax claims of any kind would not be allowed as compensation for the special or additional contributions. Both contributions would be payable at the time for paying the balance of the corporate income tax.

However, an installment or estimated payment equal to 95% of both contributions, based on an estimate of the amounts due, would be payable at the same time as the last payment of the corporate income tax installment and, for taxpayers with a financial year ending on 31 December 2017, the payment would be due on or before 20 December 2017. Interest for late payments would normally be due if the rate was underestimated by at least 20% and amounted to at least € 1.6 million.