Foreign founders often ask a deceptively simple question: once a company has been incorporated in France, what must be paid, declared and documented during the first year? The answer is not limited to one annual tax return. A French subsidiary may be liable for corporate income tax, known as impôt sur les sociétés or IS, while a branch or another foreign company may be taxed according to the profits attributable to its French activity. The business may also have to deal with the cotisation foncière des entreprises, or CFE, the French business property tax, as well as value added tax, payroll reporting and accounting obligations.

This guide focuses on the tax calendar and the evidence that a foreign-owned company should organise from day one. It does not replace advice on an individual’s immigration or personal tax position. It is designed as a practical companion to the broader company-formation roadmap for foreign founders: the question here is what happens after the structure has been chosen and the French activity begins. The key risks are usually missed registrations, an incorrect analysis of a permanent establishment, poorly documented dealings with the foreign parent and a first filing prepared too late.

The rules below distinguish a French subsidiary from a branch, identify the first-year deadlines by trigger rather than guesswork, and explain why the French tax office will examine substance, people, contracts and decision-making. Each legal reference is linked to an official source consulted for this article. Tax forms and online procedures can change, so the responsible officer should confirm the current form, account and payment date before submitting anything.

I. How does French corporate tax apply to a foreign-owned company?

A. What does a foreign-owned company pay in France: IS, CFE and related taxes?

The first distinction is between the company’s legal form and the tax territory in which its profits are treated as arising. A French société par actions simplifiée, or SAS (a simplified joint-stock company), and a French société à responsabilité limitée, or SARL (a limited liability company), are normally French taxpayers because they are incorporated and operate in France. A foreign company operating through a French branch does not become identical to a subsidiary. Its French tax position depends on the activity carried on in France, the relevant tax treaty and the profits attributable to that activity.

For an ordinary French subsidiary, the main corporate tax is IS, meaning impôt sur les sociétés, the French corporate income tax. Article 209 of the Code général des impôts, or CGI (the General Tax Code), sets the territorial starting point. The official Article 209 text refers to les bénéfices réalisés dans les entreprises exploitées en France. In practical terms, the accounting result must be adjusted under French tax rules, and the company must identify which income and expenses belong to the French business. The rule is not a licence to move French profit to a foreign parent by contract alone. Substance, functions, assets, risks and the actual performance of the work remain relevant.

Article 219 of the CGI provides the normal rate. The official Article 219 text states: Le taux normal de l’impôt est fixé à 25 %. That rate is applied to taxable profit, not simply to gross revenue or cash received in a bank account. Certain companies may qualify for a reduced rate on a limited slice of profit if statutory conditions are satisfied. A foreign shareholder should not assume that a reduced rate applies merely because the French company is small, newly incorporated or funded by an overseas group. The shareholding, turnover, capital and ownership conditions must be tested against the current official rules, including the guidance on the French corporate income tax rate and filing process.

The tax base starts with reliable accounts. The company should separate French revenue, reimbursed expenses, management fees, intellectual-property charges, financing costs, payroll and shareholder transactions from the outset. A foreign group may use consolidated reporting, a foreign chart of accounts or management reporting in another currency, but the French entity still needs records that support its French accounts and tax return. Exchange rates, intercompany invoices and accruals should be traceable. A missing invoice or an unexplained year-end provision is more difficult to defend when the first accounts are reconstructed months later.

The accounting obligation is not merely an internal preference. Article L123-12 of the French Commercial Code states that a trader must record the movements affecting the business’s assets and liabilities. The official text begins: Toute personne physique ou morale ayant la qualité de commerçant doit procéder à l’enregistrement comptable des mouvements affectant le patrimoine de son entreprise. The same framework requires annual accounts at the close of the financial year. The full provision is available in the official text of Article L123-12 of the Commercial Code. For a foreign-owned company, this makes the relationship between the French accounting file and the parent’s reporting package an important governance issue.

CFE is a separate concept. CFE means cotisation foncière des entreprises, the business property tax assessed by the local public authority. It is not a second corporate income tax and it is not calculated simply by applying the IS rate to profit. Its assessment can depend on the company’s premises, the taxable rental value of property used for the activity and, in some situations, a statutory minimum base. A company with little or no profit can still face CFE once the relevant exemption period ends. A company working from a serviced office, a home address, a warehouse or several sites should document which premises it uses and under what contract.

French guidance explains the practical scope of the tax through the Service-Public page on CFE. The administration generally looks at whether a person or company carries on a habitual non-salaried activity in France. The exact amount depends on facts that should be checked with the competent tax office, including the premises and local rate. The first year is treated differently from later years, but the filing that records the premises remains important; a first-year exemption from payment does not mean the company can ignore CFE information.

Value added tax is another separate stream. French VAT is called taxe sur la valeur ajoutée, abbreviated TVA. A company can be liable for TVA even when its IS result is low, and the VAT treatment of services supplied by a foreign parent is not the same as the treatment of domestic sales, imports or intra-European transactions. A foreign-owned company should decide, before invoicing, whether it is selling goods, services, digital services, agency services or a transfer of costs. It should also identify the customer’s status and country. The VAT registration, invoicing and return calendar must be managed separately from the IS calendar.

Payroll produces another set of obligations. A company that hires an employee may need a prior hiring declaration, known as déclaration préalable à l’embauche or DPAE, filed with URSSAF. URSSAF is the French network that collects social security contributions; the acronym comes from Unions de recouvrement des cotisations de sécurité sociale et d’allocations familiales. Monthly payroll information is generally transmitted through the déclaration sociale nominative, or DSN (the nominative social declaration). These are not substitutes for the company’s tax filings. A budget that includes only IS and CFE is incomplete if the French entity employs staff or pays a director under a French social-security regime.

The company also needs to distinguish taxes paid by the company from taxes withheld or reported for another person. A director’s remuneration, employee income tax withholding, dividends, interest, royalties and cross-border services can each trigger a different reporting question. The correct answer depends on the payment, the recipient, the applicable treaty and the supporting documents. Keeping a single spreadsheet called “tax” without separate owners for IS, CFE, TVA, payroll and withholding is a common cause of missed actions.

Finally, legal registration data has tax consequences. The RNE is the registre national des entreprises, or National Register of Enterprises. The RCS is the registre du commerce et des sociétés, or Trade and Companies Register. The Kbis is the official extract evidencing key registered information for a commercial company. INPI, the Institut national de la propriété industrielle, operates the online business formalities portal. A change of registered office, activity, director or establishment can alter the tax office’s records, the CFE file or the analysis of where the company is operated. The BODACC, the Bulletin officiel des annonces civiles et commerciales, is the official bulletin used for certain legal announcements. These terms should be understood by the foreign parent’s legal and finance teams because they appear in French onboarding documents and official correspondence.

B. When does a foreign parent create a French taxable presence?

A foreign group should not decide its French tax exposure only by asking whether a French subsidiary has been incorporated. The more useful question is: where are the functions that generate the French revenue or support the foreign company’s business actually performed? A branch, a dependent agent, a sales team, a project office, a warehouse or a person authorised to negotiate may change the analysis. A French subsidiary can also have its own IS liability while the foreign parent separately faces an argument that it has a French permanent establishment.

“Permanent establishment” is the English expression commonly used for établissement stable. It describes a taxable presence of a foreign enterprise in France under domestic law and, where relevant, an applicable tax treaty. The analysis is fact-specific. A French address on a website does not automatically create a permanent establishment, and the absence of a formal branch does not automatically prevent one. Investigators will look at the premises used, who works there, whose instructions they follow, who signs or negotiates contracts, whether the activity is preparatory or central, how long a project lasts and whether the foreign head office genuinely performs the key functions.

The French Supreme Administrative Court, the Conseil d’État, illustrated this approach in its decision of 5 July 2022, no. 458293. The official decision is available at CE, 5 July 2022, no. 458293. The court examined personnel dedicated to work in France, while the foreign headquarters mainly received contractual documents and issued invoices. It referred to un agent dépendant disposant des pouvoirs d’engager la société, caractérisant l’existence d’un établissement stable dont les bénéfices étaient imposables en France. The point is operational: a person in France with authority to commit the foreign company can matter more than the label used in the group chart.

Another important reference is the Conseil d’État decision of 11 December 2020, no. 420174, available through CE, 11 December 2020, no. 420174. In that case, the court considered the role of a French company within the Valueclick group and the factual organisation of commercial operations. The decision refers to the fact that la société française disposait des personnels nécessaires aux opérations de commercialisation en France des produits du groupe Valueclick. This passage should not be turned into a universal presumption: the result depended on the functions, staff and contractual reality examined in the proceedings. It does, however, show why a parent should map substance rather than rely on a formal statement that a French entity is “only a service company”.

Digital and cross-border models create additional uncertainty. The Conseil d’État’s decision of 4 April 2025, no. 461220, available at CE, 4 April 2025, no. 461220, discusses the evolution of the permanent-establishment analysis in a digital context. The decision notes that la jurisprudence n’avait adapté la notion traditionnelle d’établissement stable à l’économie numérique que postérieurement aux années en litige. The reference is useful for risk assessment because it shows that the timing of the activity, the period audited and the legal framework applied to that period can all matter. A group should preserve the evidence that existed when a business model was implemented, not only a later policy document drafted for an audit.

The foreign parent should therefore prepare a functional map. List each contract, the person who negotiated it, the person who approved it, the place where the work was performed, the entity that bore the commercial risk and the entity that received the economic benefit. Then compare the map with the intercompany agreement. If the agreement says that the French company performs limited marketing support but the same French team sets prices, closes sales and manages customer delivery, the paper and the facts do not align. That gap can affect the allocation of taxable profit, VAT treatment, payroll and the parent’s permanent-establishment risk.

Transfer pricing is part of the same exercise. Transfer pricing means the prices used for transactions between related companies. Article 57 of the CGI gives the administration a power to correct profits where value is transferred out of France through related-party pricing. The official text states that les bénéfices indirectement transférés à ces dernières, soit par voie de majoration ou de diminution des prix d’achat ou de vente, soit par tout autre moyen, sont incorporés aux résultats accusés par les comptabilités. The full provision is linked here: Article 57 of the CGI.

A practical transfer-pricing file should explain what the French company does, what it does not do, which assets it uses and which risks it controls. It should show the pricing method, the allocation key for shared services and the evidence supporting the invoices. A management fee based on a round percentage of French turnover is not automatically wrong, but it should have a business explanation. The parent should also keep evidence of services actually received: work product, reports, board approvals, software access, travel records, customer tickets or other material appropriate to the activity. A one-line invoice for “strategic support” is weak evidence if a significant share of the French profit is paid away.

Dividend and financing flows require their own review. A French subsidiary may pay dividends only after the relevant corporate approvals and after accounting for distributable profit. Interest on a shareholder loan should reflect the loan terms, the borrower’s capacity and the applicable rules. Royalties for software, a brand or technical know-how need a clear licence and a defensible valuation. Withholding tax and treaty relief can require forms, certificates of residence and beneficial-owner analysis. These issues are not solved by the fact that the parent is located in a country with which France has a tax treaty; the transaction, recipient and procedural evidence still matter.

A group tax-consolidation option may be relevant later, but it should not be assumed at incorporation. Article 223 A of the CGI allows a qualifying parent company to elect to become liable for IS on the results of a group in which the required ownership conditions are met. The official text of Article 223 A refers, among other conditions, to a parent and subsidiaries in which it holds at least 95% of the capital. A foreign parent does not automatically fit the French group-tax regime. The eligibility, election, ownership chain and filing consequences require a separate analysis.

The safest approach is to make the tax presence auditable. Keep the French lease or office agreement, an organisation chart, powers of attorney, director minutes, employee role descriptions, intercompany agreements, invoices, board approvals, customer contracts and a calendar of filings. If the French entity is intended to be the contracting party, its personnel and decision-making should support that intention. If the foreign parent contracts directly, the group should document why the French team does not have authority to bind it and how the work remains within the agreed scope. The aim is not to create paperwork for its own sake; it is to make the commercial reality intelligible before a dispute or audit.

II. What is the first-year tax calendar for a French company?

A. Which registrations and declarations should be completed after incorporation?

The first year should be managed as a sequence of triggers. The company’s incorporation date, the start of activity, the opening of the financial year, the first invoice, the first employee and the date it begins using premises are not necessarily the same. Each can activate a different obligation. A foreign parent should assign an owner and a backup owner to every line of the calendar, with access to the French online accounts and a copy of the submitted form or acknowledgement.

Start with the formalities file. The INPI one-stop portal is used for many business formalities, and the resulting registration information feeds the RNE and, for commercial companies, the RCS. Keep the registration receipt, the statutes, the appointment of the director, the registered-office evidence and the Kbis once available. The Kbis is often requested by banks, customers and public bodies, but it is not itself a tax return. If the activity, address or legal representative changes, update the formalities and then check whether the tax office’s records have also been updated.

The French tax administration’s page on registration for French corporate income tax identifies the operations concerned, the competent service and the documents to provide. A foreign company may need a French tax registration even where it has no French subsidiary, depending on the operation and its French tax obligations. A new French subsidiary should not wait for the first tax notice to ask who is responsible for its IS file. Identify the SIE, the service des impôts des entreprises or business tax office, and confirm the company’s tax account, correspondence address and electronic access.

The tax account should be checked against the company’s real activity. Verify the legal name, registered address, activity description, financial year-end, VAT status, contact email and bank details. If the company has a foreign parent, the administration may ask for the incorporation documents, the ownership chain, the director’s identity and explanations of the French activity. Keep a translated or bilingual internal pack, while submitting documents in the format requested by the administration. Do not send inconsistent descriptions to the INPI, the SIE, the bank and the payroll provider.

CFE requires a separate first-year action. Article 1477 of the CGI provides that taxpayers must declare the information used to establish CFE by a statutory date, and it refers to the second business day after 1 May in the relevant annual declaration cycle. The official provision states: Les contribuables doivent déclarer les éléments servant à l’établissement de la cotisation foncière des entreprises. Read the current form and instructions with the company’s creation date and establishment history. The relevant form can depend on whether the company is newly created, moving premises, changing operator or opening another establishment.

Article 1478 of the CGI contains the first-year rule. It states: En cas de création d’un établissement autre que ceux mentionnés au III, la cotisation foncière des entreprises n’est pas due pour l’année de la création. The official reference is Article 1478 of the CGI. This is a rule about whether CFE is due for the creation year, not a reason to omit the declaration of premises. Record the date the activity started, the address actually used, the surface or rental information requested and whether the company worked from several locations. If the company was formed in one year but began using a French establishment in another, ask the SIE how the facts are classified rather than applying the exemption automatically.

Premises deserve special care for a foreign founder working from a flexible office. The contract may grant a desk, a meeting room or a mailing address without giving the company exclusive use of a defined area. The CFE declaration should reflect the official instructions and the actual arrangement. Keep the contract, invoices and correspondence identifying the space. If a group employee works from home or from a customer’s premises, that does not automatically answer whether the company has a taxable establishment, but it should be recorded in the functional map used for permanent-establishment analysis.

Accounting should be opened before the first transaction. Choose the financial year-end, create accounts for French sales and purchases, configure the invoice sequence, agree the exchange-rate policy and identify who approves intercompany entries. The company should retain bank statements, supplier invoices, customer invoices, contracts, expense claims and evidence of services. If the foreign parent pays a French cost, record whether it is a capital contribution, a shareholder loan, a recharge, a reimbursable expense or a payment made on behalf of the subsidiary. Those labels have different accounting and tax effects.

The first VAT decision should be made with the first commercial contract, not after the first invoice. Confirm whether the company is subject to French TVA, whether an exemption or franchise applies, whether the customer is a business or an individual, and whether the place of supply is France or another country. “VAT number” is not a substitute for the legal analysis. Keep proof of customer status, transport, import documents and the reason for the selected VAT treatment. The French tax calendar can fail even when the IS return is correct if VAT invoices and returns are not reconciled to the ledger.

If the company hires, add the social calendar before the employment contract starts. The DPAE, URSSAF account, payroll set-up, workplace insurance, payslip process and DSN filing must be allocated to named people. If the director is paid, determine whether the person is treated as an employee-like officer, a self-employed worker or a foreign social-security contributor under a coordination rule. A foreign parent should not assume that paying the director from overseas removes French reporting. The facts of the mandate, the location of work and the applicable social-security rules must be reviewed.

The following table turns the first-year sequence into a working checklist:

Trigger	Action for the foreign-owned company	Evidence to retain
Incorporation and registration	Confirm the French legal form, activity, financial year, registered office and tax contact; obtain the registration evidence and Kbis when available.	Statutes, INPI receipt, RNE/RCS information, Kbis, director appointment and office contract.
Beginning of French activity	Confirm the SIE, IS registration, VAT position and the first accounting entry; reconcile the business description with the parent’s intercompany agreement.	Tax-account acknowledgement, activity memo, first contract, first invoice and accounting set-up note.
Use of premises	Prepare the CFE information and identify every French establishment or work location relevant to the file.	Lease, serviced-office agreement, surface information, opening date and CFE submission receipt.
First cross-border charge	Classify capital, loan, recharge, service fee, royalty or expense reimbursement and apply a documented transfer-pricing method where required.	Agreement, invoice, approval, calculation, payment proof and service evidence.
First employee or paid director	Set up DPAE, URSSAF, payroll and DSN responsibilities and check the social-security position.	Employment or mandate documents, DPAE acknowledgement, payroll file and DSN confirmation.
Financial year-end	Close the books, reconcile related-party balances, calculate taxable profit and prepare the first annual accounts and IS return.	Trial balance, inventory, tax computation, annual accounts, board approval and filing receipts.

This checklist is intentionally broader than a list of tax names. Foreign-owned companies often fail because the information exists in different systems but nobody reconciles it. The company secretary may hold the Kbis, the parent’s finance team may hold the intercompany agreement, the accountant may hold the tax account and the payroll provider may hold the director’s records. A monthly review during the first year should compare those records and flag any change in activity, premises, staff, pricing or ownership.

B. When are IS, CFE and the other first-year payments due?

French tax dates depend on the company’s accounting year-end and the type of filing. The responsible officer should therefore avoid copying a calendar from another company. A company with a 31 December year-end, a company with a short first financial year and a company with a year-end in June can have different filing and payment dates. The first question is always: what is the closing date of this company’s first accounting period, and what filing rule applies to that closing date?

IS is generally declared after the financial year has closed, using the company’s accounting result and the French tax adjustments. The Service-Public page on IS declarations and payment should be checked for the current filing process. The payment must be matched to the return and the company’s tax account. Keep the submitted return, the calculation file, the payment confirmation and the general-ledger reconciliation together. If the return is corrected, retain the reason and the relationship between the original and amended versions.

Article 1668 of the CGI provides the framework for IS instalments. The official text states: L’impôt sur les sociétés donne lieu au versement, au comptable public compétent, d’acomptes trimestriels déterminés à partir des résultats du dernier exercice clos. The same article contains a specific rule for newly created companies, including a first-exercise exemption from instalments in the circumstances described by the statute. That does not eliminate the first IS return or the tax due when the liability is calculated. It means that a new company must distinguish the instalment calendar from the first final payment.

In the first year, cash planning matters because the absence of instalments can create a large first payment once the first profit is known. The parent should forecast monthly profit, expected taxable adjustments and cash taxes without treating the forecast as the filing. If the company has losses, start-up costs or research expenditure, preserve the contracts and proof of commercial purpose. If it receives a capital contribution, shareholder loan or grant, classify it correctly before closing. If it pays a management fee to the foreign parent, confirm that the service exists and that the price is supportable.

CFE has a different rhythm. Article 1478 addresses whether the tax is due in the year of creation; later CFE is normally based on the company’s situation on 1 January, subject to the statutory rules and exceptions. A change of premises or activity can alter the file for a subsequent year. The official tax administration answer about CFE in the creation year and the current Service-Public guidance should be consulted together. Keep the CFE notice, the declared premises and the payment proof. If the notice appears inconsistent with the creation date or premises, contact the SIE promptly and preserve the request.

VAT should be put on its own calendar. Depending on the company’s regime, returns may be monthly, quarterly or annual, and the date can depend on the company’s tax regime and turnover. A foreign-owned company that invoices a French customer should verify the VAT treatment before the commercial team uses a template. A company supplying a foreign business from France should not assume that every invoice is French VAT-free; place-of-supply rules, evidence and reporting can differ. The parent should reconcile VAT returns to sales and purchase ledgers each month, even if the formal return is less frequent.

Payroll has the shortest operational deadline. A late DPAE or an incorrect DSN can create a social-security problem independent of the corporate tax result. The company should define who can access URSSAF, who approves payroll, who receives official notices and who covers the process when the foreign finance team is unavailable. The director’s remuneration and benefits should be checked alongside corporate accounts, because a payment can be recorded as a management fee by the parent while being treated as remuneration or an employment-related benefit in France.

Annual accounts also form part of the calendar. Article L123-12 of the Commercial Code links the annual accounts to the close of the financial year and the accounting records. The board or shareholders may need to approve the accounts and decide how profit or loss is treated. The company should then complete the required filing or exemption process for its size and legal form. A Kbis that still shows the correct director does not prove that the annual accounts, IS return, CFE declaration and VAT returns have been filed. Each obligation needs its own receipt.

Foreign-parent governance should be built around a tax closing pack. At minimum, include:

• a legal-entity chart showing the French company, the parent and the ownership percentages;
• a written description of the French activity, customers, premises, employees and authority to negotiate or sign;
• the IS computation, tax return, payment confirmation and reconciliation to the statutory accounts;
• the CFE declaration, premises evidence, notice and any correspondence with the SIE;
• the VAT return reconciliation and documents supporting cross-border treatment;
• the transfer-pricing file for services, financing, royalties and other related-party flows;
• the payroll, DPAE, URSSAF and DSN confirmations where people are employed or paid in France; and
• a written list of open questions, assumptions and deadlines for the next financial year.

This pack is particularly useful when the French company is small but the parent is large. A small French subsidiary may not have a full-time finance team, while the parent’s audit or tax department may ask for evidence months after the transaction. The pack also helps distinguish a genuine error from a disputed interpretation. If the company has received an official notice, a request for information or a proposed adjustment, preserve the envelope, the electronic timestamp and all attachments. Do not answer a technical tax question with an informal email that contradicts the contracts or accounts.

Audits and corrections can involve more than the original tax. A transfer-pricing adjustment can affect the French taxable result and raise a corresponding question in the parent’s country. A permanent-establishment finding can lead to a reconstruction of revenue, expenses and payroll in France. A CFE dispute can reveal that the administration’s premises data are outdated. A missing VAT document can change the treatment of a transaction even when the customer has already paid. Early review is valuable because it gives the group time to correct an invoice, amend a contract prospectively, file a voluntary clarification or prepare a coherent response.

When the first French year closes, compare the original business plan with the actual business. Did the French company become the sales contracting party? Did the founder or a parent employee negotiate contracts from France? Did the company use a different office? Did the parent recharge more services than expected? Did the French company begin employing people or hold stock? Each answer can affect the next year’s IS, CFE, VAT, payroll and permanent-establishment analysis. The first-year calendar should end with a review of the next year, not with the last payment receipt.

There may also be a reason to revisit the legal structure. A branch can be appropriate where the foreign company wants direct control, but its French profit attribution and permanent-establishment analysis need careful documentation. A subsidiary can ring-fence contracts and accounting, but it creates its own governance, accounts and tax calendar. An agency or service model may work where the French team has genuinely limited functions, but the actual authority and remuneration must match the model. Tax should inform the decision without being the only criterion: liability, funding, employment, customer expectations and exit plans also matter.

The practical rule is simple: make the first year measurable. Record the date of each trigger, the legal basis for the action, the person responsible, the submission date, the payment date and the evidence saved. Use the official impots.gouv.fr guidance for creating a company in France alongside the current forms and instructions. For a foreign company planning a branch, office or commercial activity in France, the Ministry of Economy’s guidance on implanting a foreign company is a useful official starting point, but it does not replace a factual review of the group’s operating model.

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Conclusion

For a foreign-owned company, the first French tax year is a coordination project. IS is only one part of the file. The company must establish where its French profit arises, document the functions carried out by the French team, manage CFE information for its premises, keep reliable accounts, determine its TVA position and operate the payroll process if people are hired or paid in France.

The most important legal distinction is between the French subsidiary’s own liability and the foreign parent’s possible French permanent establishment. The decisions of the Conseil d’État show why actual staff, authority, contracts and commercial functions matter. The tax administration will not necessarily accept a group’s labels if the operating reality tells a different story. Article 57 of the CGI also makes related-party pricing a documentation issue, not merely an invoicing issue.

A workable first-year calendar starts at incorporation and continues through every trigger: registration, IS and VAT accounts, premises and CFE information, first cross-border charge, first employee or director payment, financial-year close, annual accounts, IS return and payment. The company should save each acknowledgement and reconcile the tax records to the accounting ledger. Article 1668’s instalment rules and Article 1478’s creation-year CFE rule can affect cash planning, but neither removes the need for a complete first filing strategy.

Before the first invoice and before the first year-end, the foreign parent should ask three questions: which entity performed the work, where did the decision-making occur, and what document proves the answer? If those questions have clear, consistent answers, the company is in a stronger position to manage tax filings, explain its structure and respond to an official request. If the answers are unclear, a focused review of the structure, contracts and calendar is usually more efficient than trying to repair the file after a notice or audit.