France’s Digital Services Tax (DST), introduced in 2019, imposes a 3% levy on certain digital services revenues earned in France by companies with global revenues over EUR 750 million and French revenues above EUR 25 million.
France’s Constitutional Court (Conseil constitutionnel) delivered its ruling (Decision no. 2025-1157 QPC) on 12 September 2025 regarding the constitutionality of the country’s 3% digital services tax (DST).
The Constitutional Court upheld the digital services tax, ruling it served a valid budgetary purpose, was based on fair criteria, and did not violate constitutional principles of equality, territoriality, or enterprise freedom.
The Court also found the 3% flat rate reasonable, rejected claims of double taxation or excessive burden, and declared the law fully constitutional.
Earlier, the case, brought forward by Digital Classifieds France, challenged the tax on grounds of constitutional violation.
The Supreme Administrative Court (Conseil d’État) had referred the matter to the Constitutional Court on 17 June 2025 for review. The referral followed a claim by Digital Classifieds France seeking a refund of DST paid for 2019, arguing the tax violates constitutional principles of equality under Articles 6 and 13 of the Declaration of the Rights of Man and of the Citizen.
Introduced in 2019, the DST applies to companies with global annual revenues exceeding EUR 750 million and French digital service revenues above EUR 25 million, targeting turnover linked to specific digital services in France.
