Tax Authorities revised the interest rates used to calculate the deductibility of shareholder loans for companies with fiscal years ending between 30 September to 30 December 2025.
The French tax authority has issued new reference interest rates for assessing the deductibility of interest paid to shareholders. The revised rates apply to companies with financial years ending between 30 September to 30 December, 2025.
Under the provisions of the first paragraph of 3° of 1 of Article 39 and Article 212 of the French General Tax Code (CGI), interest paid to shareholders on amounts they provide or leave at the company’s disposal—beyond their capital contributions—is deductible only up to a certain limit for tax purposes, regardless of the company’s legal form.
This limitation applies to all amounts provided by shareholders, whether they are managing or not, and affects companies both subject and not subject to corporate income tax, provided they carry out industrial or commercial activities. Companies operating in the money market are also subject to the limitation.
The reference rates companies may use to determine the maximum deductible interest are as follows:
| Twelve-month period | Reference rate |
| 30 Sep – 30 Oct 2025 | 4.81% |
| 31 Oct – 29 Nov 2025 | 4.73% |
| 30 Nov – 30 Dec 2025 | 4.64% |
Earlier, the tax authority published the guidance (BOI-IMG), on 8 October 2025, regarding the implementation of the global minimum tax rules for multinational and large domestic groups, as set out in Directive (EU) 2022/2523.
