Fiscal integration

About you

You are a company established in France.
You are the French branch of a foreign company.

Taxation in France

Large companies are organised into a multitude of entities present both in France and abroad.

The principle of the individuality of taxation may lead to complex tax management of these groups of companies.

To better ensure tax neutrality of these economic structures and to reinforce the competitiveness of companies, the legislator has instituted a tax regime for groups of companies.

This regime is optional and limited to a period of five years renewed by tacit agreement. It applies solely to companies subject to corporation tax under the provisions of common law.

This regime allows the French parent company of a group to be solely liable for corporation tax in the group formed by itself and, under certain conditions, its sister companies.

Strict conditions regarding the holdings of the parent company as head of the group, as well as the subsidiaries, are required to be part of the group consolidated for tax purposes.
The member companies determine and declare their tax result in the normal way without paying the corporation tax.

The overall result is determined and declared by the parent company. It is composed of the algebraic sum of the results of the member companies of the group. Offsetting losses against profits allows a mitigation of the tax burden of the group.

Tax adjustments also need to be included in the overall result to neutralise the operations performed between the member companies of the group.

Each company member of the group is jointly and severally liable for the payment of tax due by the group and, if need be, the corresponding penalties up to the limit of the tax and the penalties to which the company would be liable if the latter wasn’t a member of the group.

In recent years, under the influence of European law, the tax consolidation scheme has been amended several times to avoid discrimination against European companies not able to become part of a French tax group.

Our support

Altexis offers you support in the constitution of the tax group, in its management and, where necessary, its loss. Furthermore, specific tax problems may be encountered in the daily management of the tax group concerning certain internal operations or else in the flow of goods or services exchanged between affiliated companies established in the EU.

Our services include in particular:

  • The constitution of the group consolidated for tax purposes
  • Assistance in the resolution of management problems of the fiscal group
  • Assistance concerning questions relating to tax integration raised during an inspection