The French Senate approved the Finance Law for 2025 on 6 February 2025, following approval by the National Assembly on February 5. With both chambers’ approval, the law is adopted, pending constitutional review.

The law includes the indexation of individual income tax brackets for inflation. A new measure introduces a minimum tax rate of 20% for tax households earning over EUR 250,000 for individuals and EUR 500,000 for couples, with a differential contribution applied if the average tax rate falls below this threshold.

A temporary surtax on corporate income tax applies to companies with an annual turnover of at least EUR 1 billion. Companies with turnover between EUR 1 billion and EUR 3 billion will be subject to a 20.6% surtax, while those exceeding EUR 3 billion will face a 41.2% surtax. A temporary tax of 12% is introduced for large shipping companies under the tonnage tax regime.

The law incorporates adjustments to the Pillar 2 global minimum tax rules in line with OECD guidance. New reporting and due diligence obligations for crypto-asset service providers will take effect from 1 January 2026.

The phased elimination of the business value-added contribution (CVAE) is postponed, maintaining a top rate of 0.28% until 2027 and extending the phaseout to 2030.

The territorial economic contribution (CET) cap will remain at 1.531% of value-added until 2027 before gradually reducing to 1.25% by 2030.

A new 8% tax on share buybacks applies from 1 March 2024 for large companies with an annual turnover of at least EUR 1 billion. A temporary restriction on loss carryforwards applies to companies with deficits exceeding EUR 2.5 billion over three consecutive years. The law also introduces rules allowing tax-neutral treatment for mergers to apply to partial demergers.

This announcement was made by the French Senate on 6 February 2025.