The early-stage tax amendments to the 2026 Finance Bill include a 25% global profit tax, a doubled digital services tax with higher thresholds, increased taxes on share buybacks and dividends, a lower threshold for the global minimum tax, and expanded tax relief for SMEs.
France’s National Assembly introduced several amendments to the Finance Bill for 2026, some of which have been approved during its first reading on 30 October 2025. The changes primarily target large corporations and business groups, introducing significant tax adjustments.
The revisions detail numerous proposed tax and fiscal measures through various articles and amendments, including changes to income tax, corporate tax exemptions for businesses in priority urban areas, tax credits for specific expenditures (like home services and photovoltaic installations), and new taxes or changes to existing taxes on financial activities and exceptional dividends.
Global Profit Taxation (Amendment 1938)
A new measure ensures that a company’s global profits are taxed in France at 25%, calculated based on the proportion of its turnover generated in France relative to its worldwide turnover. This includes turnover from entities where the company holds over 50% of shares, financial rights, or voting rights (Amendment 1938).
Digital Services Tax (DST) (Amendment 655)
The DST rate is set to double from 3% to 6%, up from the initially proposed 15%. Additionally, the revenue threshold for groups subject to the DST will rise from EUR 750 million to EUR 2 billion.
Global Minimum Tax (Amendment 1866)
The turnover threshold for the global minimum tax will be lowered from EUR 750 million to EUR 500 million.
A new tax will be introduced to target dividends paid by companies with a turnover exceeding EUR 750 million. The tax applies to dividends exceeding 1.25 times the average spent in 2017, 2018, and 2019, with rates ranging from 20% to 33%.
Share Buyback Tax (Amendment 105)
The tax on share buybacks will increase significantly from 8% to 33%, applying to all companies with turnover exceeding EUR 750 million.
SME Tax Relief (Amendment 2531)
For small and medium-sized enterprises (SMEs) with a turnover below EUR 7.6 million, the taxable profit limit for the reduced corporate tax rate of 15% will increase from EUR 42,500 to EUR 100,000.
The amendments are in the early legislative stage and may face challenges in the Senate, making their approval uncertain.
Earlier, France’s parliament released the draft Finance Bill for 2026, which was submitted on 14 October 2025, proposing extending the temporary corporate surtax for large companies at reduced rates, speeding up the CVAE business tax phase-out, and updating global minimum tax rules.
