The new Finance Law 2025 has introduced the following three points: the creation of an exceptional corporate tax contribution for large companies (I), the lowering of the VAT exemption thresholds from 1 March 2025 (II) and finally the abolition of the CVAE, postponed to 2030, and the creation of an additional contribution for 2025 (III).
I/ The extraordinary corporate tax contribution for large companies
The extraordinary contribution to the corporate income tax for large companies is a temporary additional tax introduced by Article 48 of the 2025 Finance Law.
It applies to companies subject to corporate income tax with sales of €1 billion or more in the first financial year ending on or after 31 December 2025.
This contribution is based on the amount of corporate income tax due for that financial year and aims to contribute to the recovery of public finances.
For tax-integrated groups, the parent company is responsible for paying this contribution.
Tax credits and tax receivables cannot be offset against this contribution (article 235 ter ZAA of the French tax code).
The contribution must be paid spontaneously to the competent public accountant no later than the date set for the payment of the balance of the corporate income tax (Article 1668 B of the General Tax Code).
II/ Lowering of the VAT exemption thresholds from 1 March 2025
From 1 March 2025, a single basic VAT exemption threshold of €25,000 in annual turnover will be introduced, regardless of the nature of the activity carried out.
However, this reform has been suspended until 1 June 2025 to allow time for stakeholder consultation.
The current thresholds of €85,000 for the sale of goods, €37,500 for the provision of services and €35,000 for lawyers, authors and performers will therefore continue to apply.
If the turnover limit for the current year is exceeded, the exemption will cease to apply from the date the limit is exceeded (Article 293 B of the General Tax Code).
The exemption does not apply to transactions covered by Article 257, Article 298 bis and transactions subject to VAT by virtue of an option under Articles 260, 260 A and 260 B for the supply of new means of transport (Article 293 C of the General Tax Code).
The exemption also does not apply when the tax authorities have drawn up an official report on tax evasion or when the taxable person is involved in a hidden activity (Article 293 BA of the General Tax Code).
Taxable persons established in the EU can benefit from the basic tax exemption scheme in their country of establishment and in other Member States under certain conditions.
III/ CVAE cancellation postponed to 2030 and creation of an additional contribution for 2025
The abolition of the CVAE, originally planned for 2025, has been postponed to 2030.
The rate of CVAE will be gradually reduced until 2029.
At the same time, an additional contribution to the CVAE has been introduced in 2025.
This contribution will be payable by companies that have to pay CVAE for 2025 and the rate is set at 47.4% of the CVAE payable for that year.
The details of this additional contribution are set out in Article 62 of the Finance Law for 2025, in particular with regard to the basis, rate and conditions for payment.
Med venlig hilsen / Kind regards
Cabinet Nicolas BRAHIN
Advokatfirma i NICE, Lawyers in NIC
Camilla Nissen MICHELIS
Assistante – Traductrice
1, Rue Louis Gassin – 06300 NICE (FRANCE)
Tel : +33 493 830 876 / Fax : +33 493 181 437
Camilla.nissen.michelis@brahin-avocats.com
www.brahin-avocats.com
