You have just received a letter from the French tax office for your French company, or your accountant has warned you that the first corporate tax bill is about to land, and you live hundreds or thousands of kilometres away. The amount looks large, the deadlines are expressed in form numbers you have never seen, and nobody told you that French corporate tax is paid in advance, before the final profit is even known. This is the single most common tax shock reported by foreign founders in France: the bill arrives as four advance payments plus a balance, each with its own date, and missing one triggers automatic interest and a surcharge with no prior hearing. This guide explains, in plain English and step by step, how French corporate income tax works for a company owned or run from abroad, how to pay it on time from another country, and how to fight back when the administration reassesses you. Every French acronym is explained on first use, every decisive rule is quoted from its official text with a link, and the reasoning follows two court decisions that show exactly where foreign-owned companies win and where they lose.<\/p>\n
French corporate tax is called IS, for imp\u00f4t sur les soci\u00e9t\u00e9s. The existence of the tax is stated in a single provision establishing a tax on all profits made by the companies and legal persons listed in Article 206, and giving that tax the name of corporate income tax. That provision is Article 205 of the CGI<\/a>, the CGI being the Code g\u00e9n\u00e9ral des imp\u00f4ts, the French General Tax Code that contains almost all French tax rules. The companies concerned are listed in Article 206 of the CGI<\/a>: “sont passibles de l’imp\u00f4t sur les soci\u00e9t\u00e9s, quel que soit leur objet, les soci\u00e9t\u00e9s anonymes, les soci\u00e9t\u00e9s en commandite par actions, les soci\u00e9t\u00e9s \u00e0 responsabilit\u00e9 limit\u00e9e n’ayant pas opt\u00e9 pour le r\u00e9gime fiscal des soci\u00e9t\u00e9s de personnes”, alongside cooperatives and public bodies. In practice, this means your SAS (soci\u00e9t\u00e9 par actions simplifi\u00e9e, the flexible joint-stock company most foreign founders choose) or your SARL (soci\u00e9t\u00e9 \u00e0 responsabilit\u00e9 limit\u00e9e, the classic limited liability company) becomes liable for IS automatically on the day it is registered at the RCS (Registre du commerce et des soci\u00e9t\u00e9s, the commercial register kept by the greffe, the clerk’s office of the commercial court). From that day it also receives a SIREN number, its unique nine-digit business identifier, and it is attached to a SIE (Service des imp\u00f4ts des entreprises, the local corporate tax office that collects IS and VAT). The official service-public guide confirms the mechanics of payment in detail at Imp\u00f4t sur les soci\u00e9t\u00e9s : rates, return and payment<\/a>.<\/p>\n The rate is straightforward. Article 219 of the CGI<\/a> states: “Le taux normal de l’imp\u00f4t est fix\u00e9 \u00e0 25 %.” Twenty-five percent of the taxable profit, called the r\u00e9sultat fiscal, goes to the French Treasury. The taxable profit is not the accounting profit: starting from the accounts kept under French accounting rules, your accountant adds back non-deductible items such as fines, the IS itself and part of company-car costs, then subtracts tax-only deductions, to reach the figure the 25 percent rate hits. A reduced 15 percent rate exists on the first 42,120 euros of profit for small companies, but it requires capital held for at least 75 percent by individuals, so a French subsidiary owned by your foreign holding company is generally taxed at the full 25 percent from the first euro. Budget for that rate before you promise dividends to yourself, because the IS is computed and paid long before any distribution.<\/p>\n The timing is what surprises foreign owners, because French IS is paid in advance, in four instalments, before the year even ends. Article 1668 of the CGI<\/a> provides: “L’imp\u00f4t sur les soci\u00e9t\u00e9s donne lieu au versement, au comptable public comp\u00e9tent, d’acomptes trimestriels d\u00e9termin\u00e9s \u00e0 partir des r\u00e9sultats du dernier exercice clos.” Each instalment, called an acompte, is computed from the previous financial year, called the exercice, and is paid with form 2571, the relev\u00e9 d’acompte, exclusively online. The official calendar sets each payment on a fixed date: 15 March, 15 June, 15 September and 15 December, with the exact mapping depending on when your exercice closes. Companies whose IS is below 3,000 euros pay in one go and skip the instalments. A newly created company, with no previous exercice, is exempt from instalments during its first year and pays everything as a balance, called the solde, with form 2572, the relev\u00e9 de solde. That first-year balance is due no later than the 15th of the fourth month after the exercice closes, which means 15 May of the following year for the standard 31 December year-end, and it is often the painful lump sum founders discover fifteen months after launch. The annual return itself, form 2065 with its annexes forming the liasse fiscale, the full tax pack, is filed with the SIE in the same window. Any overpayment is refunded automatically within thirty days of the relev\u00e9 de solde or credited against the next acompte, so paying slightly too much in advance is never lost money, only a cash-flow cost.<\/p>\n Three cash-flow reflexes follow directly from these rules. First, provision 25 percent of every euro of pre-tax profit from month one, because that money belongs to the Tr\u00e9sor public, the French Treasury, and the first-year balance can coincide with the first instalments of year two in the same quarter. Second, align your French exercice with your foreign parent’s year-end whenever the articles allow it, so consolidation and the transfer-pricing documentation, the file proving that prices charged between your French company and its foreign parent are arm’s length, run on a single calendar. Third, open the company’s espace professionnel, its online professional tax account on impots.gouv.fr, which runs an English-language section for international users<\/a>, in the first month after the Kbis arrives. The Kbis is the official birth certificate of your company issued by the greffe, and without the online account nothing can be filed or paid. Founders who leave this step to the fourth quarter routinely discover that no return was ever filed, and the penalties described below then apply on top of the tax itself. Readers building the whole structure step by step should start with our hub guide on setting up a company in France as a foreign founder: bank account, Kbis, VAT and first hire<\/a>, and keep the yearly rhythm described in our annual legal calendar for French companies run from abroad<\/a>.<\/p>\n Everything is paid online, and from abroad that is good news once the access works. Instalments go through the relev\u00e9 d’acompte 2571 and the balance through the relev\u00e9 de solde 2572, filed electronically either by manual entry in EFI mode, where the company types the form itself on the portal, or by data transfer in EDI mode, where your expert-comptable, the French chartered accountant, transmits the file from professional software. Most foreign-owned companies use EDI through their accountant, which means the critical task for the director abroad is not learning the portal but mandating the accountant early, checking that each deadline is met, and keeping funds available on the French company account a week before the 15th. The SIE debits or records the payment without any prior court decision, so a missed deadline is never a matter for discussion afterwards: the sanctions apply automatically, and only a formal claim can undo them.<\/p>\n Late payment carries two layers of cost that stack on each other. First, late-payment interest, called int\u00e9r\u00eat de retard, accrues month by month on any tax claim not paid by the legal deadline. Article 1727 of the CGI<\/a> states: “Toute cr\u00e9ance de nature fiscale, dont l’\u00e9tablissement ou le recouvrement incombe aux administrations fiscales, qui n’a pas \u00e9t\u00e9 acquitt\u00e9e dans le d\u00e9lai l\u00e9gal donne lieu au versement d’un int\u00e9r\u00eat de retard.” Second, a surcharge, called a majoration, punishes the delay itself. Article 1731 of the CGI<\/a> provides for a 5 percent surcharge on any delay in paying sums due to the tax accountants for taxes other than those covered by Article 1730. Five percent of the amount due, plus monthly interest, on every late acompte or solde, with no need for the administration to prove any deliberate fault. A founder who misses two instalments because the online account was never opened therefore pays the tax, the interest and the surcharge, and learns about all three at once when the mise en demeure, the formal demand letter, reaches the registered office.<\/p>\n If the money is short, do not simply skip the payment in silence. Underestimating an acompte deliberately exposes the company to the same surcharge when the final liquidation shows the instalments were too low, and silence destroys the credibility you will need later to negotiate. The workable route is a request for a payment schedule, called a d\u00e9lai de paiement, filed with the SIE before the deadline where possible, supported by cash-flow documents and a concrete timetable, while the undisputed part of the tax is paid immediately. Partial payment on time plus a reasoned request beats total default in every subsequent discussion, including before the judge. Keep proof of every transfer, every portal confirmation and every letter from the SIE, because the challenge procedure described in Part II rewards the company that can show a clean payment history and punishes the one that cannot. And never confuse the IS diary with the VAT diary: VAT, the taxe sur la valeur ajout\u00e9e collected on sales, runs on separate forms and a separate calendar at the same SIE, and our guide on VAT numbers, CA3 returns and refunds for foreign-owned companies<\/a> covers that track in full.<\/p>\n A reassessment, called a redressement, never starts with a bill. It starts with a proposition de rectification, a reasoned proposal in which the administration states what it intends to add to your taxable profit and why. When the SIE considers that your return understates the tax, for example after a v\u00e9rification de comptabilit\u00e9, the audit of your accounts, or after comparing your margins with comparable companies, it must follow the contradictory procedure defined by statute. Article L55 of the LPF<\/a>, the LPF being the Livre des proc\u00e9dures fiscales, the French Tax Procedure Code, provides that “lorsque l’administration des imp\u00f4ts constate une insuffisance, une inexactitude, une omission ou une dissimulation dans les \u00e9l\u00e9ments servant de base au calcul des imp\u00f4ts”, then “les rectifications correspondantes sont effectu\u00e9es suivant la proc\u00e9dure de rectification contradictoire d\u00e9finie aux articles L. 57 \u00e0 L. 61 A.” That procedure is your shield, and it works even if you live abroad, provided you use it in time.<\/p>\n The core of the shield is the duty to give reasons. Article L57 of the LPF<\/a> requires the administration to send the taxpayer a reassessment proposal reasoned precisely enough for the taxpayer to submit observations or accept it. The proposal must therefore be reasoned precisely enough that you can reply to it, and the courts enforce this strictly: a vague proposal that does not let the company understand the amount, the year and the legal basis can be annulled, wiping out the reassessment with it. The courts apply exactly this test, as the Colmar Court of Appeal recalled on 29 January 2025 (RG 23\/01002) when the taxpayers argued that the proposal against them stated neither the precise nature nor the precise origin of the material relied upon: the court restated the Article L57 duty to give reasons allowing observations or acceptance, and added that the administration must also give reasons when it rejects the taxpayer observations. In that case the taxpayers ultimately lost because the procedure was found regular and the tax well-founded, the judgment of 15 December 2022 being confirmed in full, which is precisely the lesson: courts examine the procedure first, and only a demonstrably irregular proposal gets you discharged.<\/p>\n You have thirty days from receipt of the proposal to send observations, extendable by a further thirty days on request made before the first period expires. For a director living abroad, three practical steps decide everything. First, organise receipt: the proposal goes to the si\u00e8ge social, the registered office, so give your domiciliation agent or accountant written instructions to forward any tax letter within 48 hours, and never let the registered-office address become a mailbox nobody opens. Second, request the extension systematically and in writing before the deadline, because thirty days evaporate when documents must travel between countries. Third, demand the documents the administration relied upon: Article L76 B of the LPF<\/a> requires the administration to inform the taxpayer of the content and origin of third-party information and documents on which it relied, and to send a copy of those documents before enforced collection to any taxpayer who asks for them. If the reassessment uses bank data, supplier invoices or information from another company, you are entitled to see them before the tax is collected, and a refusal can taint the whole procedure. Send your observations by registered letter with acknowledgment of receipt, in French, addressing each ground one by one with exhibits numbered to match, and keep the postal proof: from abroad, the date of dispatch recorded by the carrier is often what saves you.<\/p>\n If the SIE maintains the reassessment, you may seize the commission d\u00e9partementale des imp\u00f4ts, the departmental tax board, for questions of fact such as margins or valuations, then file a r\u00e9clamation contentieuse, the formal administrative claim, and finally appeal to the tribunal administratif, the administrative court. Each step has its own deadline, counted from the previous decision, and missing one closes the door permanently. A lawyer in France can handle the entire chain under a power of attorney while you remain abroad, which is how most foreign directors litigate: presence in France is not required, but representation and deadlines are non-negotiable.<\/p>\n Normally the administration must prove the grounds of its reassessment, but several situations reverse the burden, and foreign-owned structures hit them more often than others. The general reversal is automatic taxation, called taxation d’office: when a company files no return, files outrageously late, or refuses to answer a formal information request, the SIE assesses the tax unilaterally, and Article L193 of the LPF<\/a> then provides: “Dans tous les cas o\u00f9 une imposition a \u00e9t\u00e9 \u00e9tablie d’office la charge de la preuve incombe au contribuable qui demande la d\u00e9charge ou la r\u00e9duction de l’imposition.” The company that wants the assessment cancelled must therefore prove the exact correct figure, with complete accounts and documents, instead of merely criticising the administration’s method. From abroad, taxation d’office typically follows the unopened-mailbox scenario: returns never filed because nobody monitored the registered office, then a unilateral assessment, then the shock discovery that the burden has flipped. The only cure is prevention, keeping the filing chain alive, and if the damage is done, reconstructing full, credible accounts immediately rather than arguing in the abstract.<\/p>\n The second trap concerns foreign entities holding French real estate. Any legal entity, French or foreign, that owns property in France may face the annual 3 percent tax on the market value of that property. Article 990 D of the CGI<\/a> provides: “Les entit\u00e9s juridiques : personnes morales, organismes, fiducies ou institutions comparables qui, directement ou par entit\u00e9 interpos\u00e9e, poss\u00e8dent un ou plusieurs immeubles situ\u00e9s en France ou sont titulaires de droits r\u00e9els portant sur ces biens sont redevables d’une taxe annuelle \u00e9gale \u00e0 3 % de la valeur v\u00e9nale de ces immeubles ou droits.” Exemptions exist, notably for entities that disclose their shareholders to the French administration, but they are interpreted strictly, and the proof lies on the entity. The Court of Cassation confirmed this on 12 October 2022 (Commercial Chamber, appeal 20-14.073, published in the Bulletin) in the case of Cobos, a Luxembourg company owning property at Saint-Jean-Cap-Ferrat that claimed exemption for 2010 to 2012. The Court held that a company claiming discharge under Article 990 E, 3\u00b0 of the CGI must prove the economic reality of the shareholding it invokes, and it upheld the appeal court finding that Cobos had not discharged that burden under Article L193 LPF where the assessment had been issued automatically. The judges accepted that such proof may be made by any means, including financial flows matching the transactions, yet on the facts the private deeds, the self-kept share register and the notarial certifications were held insufficient, because they emanated from the company itself without corroborating filings, tax declarations or payment records. For a foreign founder, the message is blunt: holding French offices or flats through a foreign company without a documented, declared shareholder chain converts a planning idea into an annual 3 percent charge on the full market value, and reconstructing the proof years later in court almost always fails.<\/p>\n Draw the operational conclusions. Keep the French company’s accounts, bank statements, intra-group contracts and transfer-pricing file complete and consistent every year, so that no reassessment can push you into taxation d’office and no auditor can claim your documents do not exist. If you hold French property through a foreign entity, file the shareholder disclosures on time and keep the payment trails proving who owns what, because the Cobos ruling shows that self-produced paperwork alone does not convince French judges. If a proposition de rectification arrives, answer it within the extended deadline with numbered exhibits, demand the third-party documents under Article L76 B, and escalate through the claim and court stages without missing a date. Companies that do this from the first letter regularly obtain reductions or cancellations; companies that ignore the mail until the mise en recouvrement, the enforced collection, pay the tax, the interest, the surcharge and the collection costs. Distance from France explains nothing to the judge and excuses nothing in the calendar.<\/p>\n French corporate tax for a company run from abroad is a discipline, not a lottery. The 25 percent IS rate applies to your SAS or SARL from registration day, it is collected in four advance instalments computed on the previous year with the balance at filing time, and every payment travels through the online professional account that must be opened in the first month. Late payment automatically adds monthly interest and a 5 percent surcharge, with no hearing beforehand, so diary discipline and an early mandate to your accountant matter more than any argument about fairness. When the administration reassesses you, the contradictory procedure gives you real weapons: a proposal that must be reasoned enough to answer, thirty days plus thirty more to reply, access to the third-party documents used against you, and escalation from the departmental board to the administrative court. But those weapons only work if your mailbox is monitored, your deadlines are met and your proof is ready, because automatic taxation flips the burden onto you and foreign property structures face the strictest proof standard of all. Organise receipt of tax mail today, provision the tax monthly, and answer every proposal in writing and on time.<\/p>\n Telephone consultation: 80 EUR incl. VAT, within 48 hours with an attorney of the firm. Call +33 6 46 60 58 22<\/a> or write via the contact page<\/a>. Office in Paris, assisting clients throughout \u00cele-de-France and abroad.<\/p>\n","protected":false},"excerpt":{"rendered":" Foreign founder guide: French corporate tax at 25 percent, four advance payments and the final balance, online payment from abroad, late interest and surcharges, and how to answer a reassessment proposal and challenge it within the deadlines.<\/p>\n","protected":false},"author":251031309,"featured_media":16466,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_kj_source_type":"","_kj_official_id":"","_kj_official_url":"","_kj_judilibre_id":"","_kj_jur":"","_kj_lieu":"","_kj_chambre":"","_kj_rg":"","_kj_date":"","activitypub_content_warning":"","activitypub_content_visibility":"","activitypub_max_image_attachments":4,"activitypub_interaction_policy_quote":"anyone","activitypub_status":"federated","footnotes":""},"categories":[80314,80313],"tags":[],"class_list":["post-2130755","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-decryptage","category-doing-business-in-france"],"yoast_head":"\nB. How to pay from abroad without penalties: the online account, the real deadlines and the cost of paying late<\/h3>\n
II. How to challenge a French tax reassessment from abroad without losing by default<\/h2>\n
A. Answer the reassessment proposal inside the deadline: the contradictory procedure, the reasons you must receive and the documents you can demand<\/h3>\n
B. Prove your case when the burden of proof falls on you: automatic taxation, foreign entities and French property<\/h3>\n
Conclusion<\/h2>\n
Need a quick opinion on your case<\/h2>\n