{"id":2145701,"date":"2026-10-12T02:56:31","date_gmt":"2026-10-12T00:56:31","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/12\/foreign-company-france-shareholder-loan-compte-courant-interest-repay-abroad\/"},"modified":"2026-10-12T02:56:31","modified_gmt":"2026-10-12T00:56:31","slug":"foreign-company-france-shareholder-loan-compte-courant-interest-repay-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/12\/foreign-company-france-shareholder-loan-compte-courant-interest-repay-abroad\/","title":{"rendered":"Your Foreign Parent Lent Money to Your French Company and You Live Abroad: Fund, Charge Interest, Get Repaid"},"content":{"rendered":"

You wired 150,000 euros from London, New York or Dubai to keep your French company alive, and your French accountant just recorded it as a shareholder current account, in French a compte courant d’associ\u00e9<\/em>. That one accounting line decides everything that follows: whether you can charge interest, whether your French company can deduct that interest from its corporate tax, whether you can ask for the money back next month or must wait years, and what the French tax inspector will say when the transfer crosses his desk. Foreign founders usually discover these questions in the wrong order, at the worst moment, when the cash is already in France and the company needs it, or when the founder needs it back and the company refuses to pay. This article puts the order right. It explains how to lend money to your own French soci\u00e9t\u00e9 par actions simplifi\u00e9e<\/em> (SAS, the flexible joint-stock company most foreign founders choose) or soci\u00e9t\u00e9 \u00e0 responsabilit\u00e9 limit\u00e9e<\/em> (SARL, the limited liability company with stricter rules) from abroad, how to set an interest rate the tax administration will accept, how to get repaid while you live outside France, and how French courts handle the disputes that arise when repayment turns sour. Every acronym is explained, every rule is tied to its official text, and the two court decisions quoted below were read in full for this article.<\/p>\n

I. Lending money to your French company from abroad without creating a tax problem<\/h2>\n

A. How do you put money into your French company from abroad: capital increase or shareholder loan?<\/h3>\n

When cash must move from your foreign holding company or your personal account to your French subsidiary, French law offers two main roads, and they have nothing in common. The first road is equity: you subscribe to a capital increase, the money becomes the company’s property permanently, and it comes back to you one day as dividends, which follow the dividend chain described in our companion guide on getting profits out of France through dividends<\/a>. The second road is debt: you leave the money at the company’s disposal as an advance on a shareholder current account, a compte courant d’associ\u00e9<\/em>, which the company owes back to you. If you formed the company recently and still hesitate between vehicles, our pillar guide on choosing between SAS, SARL, branch and subsidiary<\/a> explains which structure fits a foreign shareholder who plans to fund the business from abroad.<\/p>\n

The shareholder loan road looks simpler, and in practice it is the one most foreign parents take, because a capital increase in a SAS or SARL requires a shareholders’ decision, an amendment of the articles of association (statuts<\/em>), and a filing with the greffe<\/em>, the clerk’s office of the commercial court that keeps the Registre du commerce et des soci\u00e9t\u00e9s<\/em> (RCS, the French companies register), while an advance on current account requires only a wire transfer and a bookkeeping entry. But simplicity at the start is exactly what produces disputes at the end. A Paris Court of Appeal decision of 28 November 2023 shows the pattern: a company based in Martinique had advanced 1,250,000 euros to a French property company, first without any written agreement, then under a current-account agreement signed months later, and the two sides spent years litigating which sums the agreement covered and when repayment was due. The court ordered the French company to pay 1,331,914 euros in principal and interest, but only after full proceedings before the commercial court and the court of appeal (Paris, P\u00f4le 5, ch. 8, 28 Nov. 2023, no. 21\/11984<\/a>). The lesson for a founder living abroad is direct: paper signed before the money moves costs little, while paper signed after the dispute starts costs a fortune.<\/p>\n

French law does not prohibit a foreign shareholder, whether an individual or a foreign company, from lending to a French company. The banking monopoly laid down in the Monetary and Financial Code states that “Il est interdit \u00e0 toute personne autre qu’un \u00e9tablissement de cr\u00e9dit ou une soci\u00e9t\u00e9 de financement d’effectuer des op\u00e9rations de cr\u00e9dit \u00e0 titre habituel” (Monetary and Financial Code, art. L.511-5<\/a>), which means lending as a habitual business is reserved to banks, but a shareholder advancing funds to its own company on an occasional basis, to support that company’s activity, falls outside that prohibition. What the law does regulate is the form of the arrangement when the lender is also a director or a significant shareholder. In a SAS, the president must present a report to the shareholders on agreements entered into directly or through an intermediary between the company and its president, one of its directors, a shareholder holding more than 10 percent of the voting rights, or the controlling company (Commercial Code, art. L.227-10<\/a>). In a SARL, the manager presents a similar report, the interested manager or shareholder may not vote, and their shares are excluded from quorum and majority calculations (Commercial Code, art. L.223-19<\/a>). Shareholders vote on the report, unapproved agreements still produce their effects, but the interested person bears any harmful consequences for the company. In a company with a single shareholder, a mere entry in the decisions register suffices. From abroad, this means one practical reflex: every advance should be documented in a dated current-account agreement, mentioned in the annual shareholders’ meeting, and the interested shareholder should abstain from voting on it in a SARL.<\/p>\n

One absolute prohibition deserves attention because foreign founders sometimes stumble into it. In a soci\u00e9t\u00e9 anonyme<\/em> (SA, the public limited company) and, by extension of the same logic that auditors apply rigorously, individual directors may not borrow from their own company, obtain an overdraft on current account, or have the company guarantee their personal debts, on pain of nullity of the contract (Commercial Code, art. L.225-43<\/a>). The direction that matters here is the reverse of our topic, money flowing from the company to the director rather than from the shareholder to the company, but founders who treat the French subsidiary’s bank account as an extension of their own wallet need to know this wall exists. Advances go from shareholder to company, never casually the other way, and every movement is recorded in the company’s books under the shareholder’s name.<\/p>\n

B. How do you charge interest that your French company can actually deduct?<\/h3>\n

A shareholder current account can bear interest or remain interest-free; nothing in French company law imposes remuneration. But if you want interest, two conditions are non-negotiable, and both must be settled in writing before the tax inspector asks. First, the rate must be fixed in writing, because the Civil Code provides that “Le taux de l’int\u00e9r\u00eat conventionnel doit \u00eatre fix\u00e9 par \u00e9crit” (Civil Code, art. 1907<\/a>). An oral understanding with yourself, as sole shareholder living in another country, has no probative value. The current-account agreement should state the principal, the rate, the computation method, whether interest is paid annually or capitalised, and the repayment terms. Second, the interest only produces its full effect if the agreement genuinely exists and is known to the company: in a 30 May 2023 decision, the Paris Court of Appeal had to decide between six expert scenarios depending on whether each shareholder’s current account had produced interest, and it upheld the interpretation that the agreement on interest is given by the manager and the holder of the account, since the clause “il ne peut que d\u00e9signer les personnes ayant un compte courant d’associ\u00e9s et qui souhaitent que les sommes vers\u00e9es sur ce compte produisent des int\u00e9r\u00eats” (Paris, P\u00f4le 4, ch. 13, 30 May 2023, no. 20\/10487<\/a>). An interest clause produced for the first time during litigation, signed by one hand and never recorded in the accounts, invites the court to discard it. Write it, sign it, book it, every year.<\/p>\n

On the tax side, the French company that pays the interest wants to deduct it from its taxable profit, which is taxed at the standard corporate rate, since “Le taux normal de l’imp\u00f4t est fix\u00e9 \u00e0 25 %” (General Tax Code, art. 219<\/a>). The deduction is governed first by the general rule that net profit is computed after deducting all charges (General Tax Code, art. 39<\/a>), then by a specific ceiling for interest paid to shareholders: interest on sums left or made available to a company by a shareholder is deductible only within the limit of the rate set by that same article 39, or a higher rate the borrowing company shows it could have obtained from independent banks under similar conditions (General Tax Code, art. 212, I<\/a>). The reference rate, commonly called the TMP (taux moyen de r\u00e9f\u00e9rence<\/em>, the average reference rate), is the annual average of the average rates for loans with initial duration over two years granted by banks to French companies, published quarterly in the Journal officiel<\/em> (the official gazette). The tax administration’s official commentary confirms the mechanics: for a financial year that matches the calendar year, the annual average is computed as the arithmetic mean of the quarterly average rates published in the Journal officiel, as explained in the BOFiP guidance on financial charges (BOFiP, BIC-CHG-50-50-30<\/a>). In plain terms, interest above that average rate is not lost out of carelessness by the drafter, it is mechanically added back to taxable profit. A foreign parent that charges its French subsidiary 8 percent when the published average sits near 5 percent simply offers the French Treasury a voluntary contribution.<\/p>\n

Two further ceilings can bite large intra-group financings, and a foreign group treasurer should know they exist even when a small SAS stays below them. The general cap on net financial charges allows deduction only up to the higher of 3 million euros or 30 percent of adjusted taxable profit (General Tax Code, art. 212 bis, I<\/a>). Below 3 million euros of net interest per year, which covers the overwhelming majority of foreign-owned SMEs, this ceiling is invisible; above it, professional modelling becomes necessary. Symmetrically, if the French company is thinly capitalised and lives almost entirely on shareholder debt, the interest can be reclassified and the arrangement challenged as abnormal management. The prudent structure for a founder abroad is therefore a mixed one: enough equity to keep the balance sheet credible, documented in the Kbis<\/em> (the official company identity extract issued by the greffe<\/em>) and the filed accounts, plus a current-account advance at a rate at or below the published average, with the agreement, the board or shareholders’ minutes, the bank transfer slips and the annual postings kept together in one file. When the inspector arrives, that file is your defence.<\/p>\n

One last question arises immediately for a non-resident lender: the interest paid by the French company to a foreign shareholder or foreign parent may suffer French withholding tax, reduced or eliminated by the applicable double tax treaty, and must be declared through the proper return with the correct treaty rate applied. The treaty analysis depends on the lender’s country of residence, the beneficial ownership of the interest, and whether the lender is an individual or a company. Because the 2026 treaty network and the forms evolve, the rate should be checked lender by lender at the time of each payment rather than assumed once and for all. What never changes is the paperwork reflex: each interest payment needs its computation sheet showing the principal, the contractual rate, the TMP ceiling for the period, and the treaty withholding applied, so that the French company’s accountant can file consistently and the foreign lender can claim treaty relief at home.<\/p>\n

II. Getting your money back while you live outside France<\/h2>\n

A. When can you demand repayment, and what do French courts do when the company refuses?<\/h3>\n

The single most valuable sentence a foreign shareholder can know about French current accounts was written by the Paris Court of Appeal: “Les comptes courants d’associ\u00e9s ont pour caract\u00e9ristique essentielle, en l’absence de convention particuli\u00e8re ou statutaire les r\u00e9gissant, d’\u00eatre remboursables \u00e0 tout moment” (Paris, P\u00f4le 5, ch. 8, 28 Nov. 2023, no. 21\/11984<\/a>). In plain English: unless a specific agreement or a clause in the articles says otherwise, your shareholder current account is repayable at any time, on your simple demand. No notice period is implied, no proof of company need is required, and the company’s financial difficulties do not by themselves suspend your right. In that 2023 case, the borrowing company argued precisely that its difficulties, caused by the health crisis and a failed property sale, made the lender’s demand untimely and contrary to the company’s interest, and asked the court for patience and for payment delays. The court rejected both: “l’int\u00e9gralit\u00e9 de la cr\u00e9ance de la soci\u00e9t\u00e9 Meil-Invest au titre du compte courant d’associ\u00e9 \u00e9tait bien exigible”, ordered payment of 1,331,914 euros with later interest until actual payment, and refused any payment delay given how long the debt had been due and the sale of the company’s only asset. A clause that makes repayment depend on the company’s financial possibilities is valid when both sides genuinely agree to it, the court accepted that such clauses exist and can bind the parties, but it construed the clause strictly, refused to extend it to advances made before the agreement, and refused to let it swallow a separate unconditional promise to repay 250,000 euros by a fixed date. Draft your blocking clause narrowly if you accept one, and never let it cover past advances by vague retroactive wording.<\/p>\n

Three practical consequences follow for a founder who lives abroad. First, decide at the time of the advance whether the money is available on demand or blocked, and write that choice down. A convention de blocage<\/em> (a lock-up agreement under which the shareholder promises not to claim repayment for a defined period) is commonly required by banks before they lend to the company, and it is also used to show the company’s auditor (commissaire aux comptes<\/em>, the statutory auditor who certifies the accounts of larger companies) that the advance is stable enough to be treated as quasi-equity. If you sign one, fix its duration, its end date, and what happens to interest during the freeze. If you sign none, your right to demand repayment at any moment remains intact, and no one can invent a freeze afterwards. Second, make the demand properly: a formal demand letter (mise en demeure<\/em>) sent by a means that proves receipt, quantifying principal and interest and setting a clear payment deadline, starts the clock for late interest and is the document the court will read first. In the 2023 case, the lender’s formal demand of 3 April 2020 for 1,301,023.65 euros within 30 days structured the entire litigation that followed. Third, know that the company’s books help you: the court noted that the current account appeared for 1,317,039.41 euros in principal and interest in the company’s own general ledger, and that neither the principal nor the interest was disputed, only their due date. Keep your own ledger, reconcile it every year with the French accountant’s postings, and any later argument that the money was a gift, a contribution, or something else collapses against the books.<\/p>\n

Enforcement from abroad follows the ordinary French civil route, which does not require your physical presence. A French lawyer can seek an order before the commercial court (tribunal de commerce<\/em>, the court for business disputes) or the judicial court (tribunal judiciaire<\/em>) depending on the parties, obtain a judgment, and enforce it through a commissaire de justice<\/em> (the enforcement officer, formerly called huissier de justice<\/em>) by seizure of the company’s bank accounts or assets. Where the debt is written, quantified in the books, and covered by an agreement, judges can also grant provisional measures, as the lender in the 2023 case did when it secured a provisional mortgage on the company’s property lots before suing for the full amount. The realistic timeline runs in months, not weeks, and the realistic cost includes court fees, lawyer fees, and the enforcement officer’s regulated tariffs, so the demand letter phase, negotiated seriously with a complete file, is where most well-documented cases settle. Founders who keep every transfer slip, every signed agreement, and every annual statement rarely need to go further; founders who wired money with a one-line email usually do.<\/p>\n

B. How do you bring the cash home cleanly without triggering a reassessment?<\/h3>\n

Repayment of principal is not income: when your French company repays the 150,000 euros you advanced, that transfer is the extinction of a debt, not a dividend and not remuneration, so it carries no French income tax charge on the principal itself in the hands of a non-resident lender. Only the interest is taxable income, subject to the withholding and treaty analysis described above. This distinction is the entire financial reason the current-account technique exists alongside dividends: dividends can only be paid out of distributable profit after the annual accounts are approved by the shareholders, while a current-account advance can be repaid as soon as the contract allows, even in a loss-making year. The two channels complement each other, and our guide on taking dividends out of France<\/a> covers the profit-distribution side of the same cash strategy. Never confuse the two in the paperwork: label every transfer explicitly as a current-account advance, an interest payment, a principal repayment, or a dividend, because a mislabelled transfer is the raw material of reassessments.<\/p>\n

The tax inspector’s standard questions on repayment are predictable, and each has a documentary answer. Is the advance genuine debt or disguised equity? The signed agreement, the interest clause at a market-consistent rate, the ledger entries in both companies’ books, and the absence of any link to the company’s profit answer that it is debt. Is the interest rate excessive? The computation sheet comparing the contractual rate with the published TMP average for the period answers that it is not. Is the borrowing abnormal because the company had no need for the funds? The company’s cash-flow plan, the investment the advance financed, or the bridge it covered answers that it did. Could the advance hide undeclared revenue of the lender? The bank transfer slips from the lender’s foreign account answer where the money came from. None of these answers requires creativity; all of them require files. The founders who suffer reassessments are almost never accused of inventing a sophisticated fraud, they are accused of being unable to produce, three years later, the agreement, the rate sheet, or the transfer slip for money that genuinely moved.<\/p>\n

Company-law hygiene completes the picture. Each year, the shareholders’ meeting that approves the accounts should also review the regulated-agreements report covering the current-account arrangement, and the minutes should record the abstention of the interested party where the rules require it. If losses have pushed equity below half of the share capital, the shareholders must decide within four months after approval of the accounts whether to dissolve the company early, and if they continue, the company must rebuild its equity by the end of the second financial year following the loss (Commercial Code, art. L.223-42<\/a>). A company kept alive purely by shareholder advances while its equity has melted away attracts the attention of auditors, banks, and courts together, and recapitalising part of the advance, by converting it into equity through a formal capital increase, is often the cleaner move. Finally, when the company repays you abroad, the transfer itself must comply with the bank’s anti-money-laundering checks: expect the French bank to ask for the agreement, the shareholders’ minutes authorising the repayment, and the lender’s identification, especially for large or first-time transfers to a foreign account. Prepare that pack before instructing the wire, not after the bank freezes it.<\/p>\n

Conclusion<\/h2>\n

Lending to your own French company from abroad is neither forbidden nor complicated, but it rewards founders who treat the advance as a real loan from day one. Sign a written current-account agreement before the money moves, fix the interest rate in writing at or below the published average so the French company keeps its deduction, record the arrangement in the shareholders’ decisions with the proper abstentions, and reconcile the postings every year. On the way back, remember that your account is repayable at any time unless you have genuinely agreed otherwise, demand repayment formally with quantified figures, and keep every slip so the repayment reads, to any inspector or judge, as the end of a documented debt rather than the beginning of a dispute. Debt and dividends together form the complete toolkit for moving money across the border in both directions; used with papers in order, they let a founder in London, New York or Dubai finance a French business with confidence and recover the investment when the time comes.<\/p>\n","protected":false},"excerpt":{"rendered":"

Shareholder loans to a French SAS or SARL from abroad: written agreement, deductible interest within the TMP cap, repayment on demand, and clean repatriation.<\/p>\n","protected":false},"author":251031309,"featured_media":16538,"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-2145701","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-decryptage","category-doing-business-in-france"],"yoast_head":"\nYour Foreign Parent Lent Money to Your French Company and You Live Abroad: Fund, Charge Interest, Get Repaid - 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