author_orbitax
Orbitax

Share This Article

France Clarifies Offset of Foreign Tax Credits in Relation to 3.3% Social Surcharge

07 March 2023

|

Approved Changes

|

France

The French tax authority has announced an update to guidance on the payment of the 3.3% social contribution surcharge that is levied on corporate income tax exceeding EUR 763,000 per year. The update concerns foreign tax credits, including that companies benefiting from foreign tax credits are free to determine the order of imputation of the credit against corporate income tax and the surcharge. In this respect, the guidance explains that although Article 235 ter ZC of the Tax Code restricts the offset of any credits against the social contribution surcharge, a foreign tax credit may offset the surcharge if provided...