Philippe Hupé and Bertrand Sers, Walter France tax partners, presented during a webinar the main provisions applying to companies in the finance law passed in February.
Introduction of an exceptional contribution on profits
An exceptional contribution to profits is created, But it only concerns large companies that achieve more than a billion turnover. It is calculated on an average of the IS (corporate tax) of the last two financial years, and its rate is 20,6% for companies with a turnover of between 1 and 3 billion euros, and 41,2% for companies with a turnover of more than 3 billion euros. There is a smoothing device to limit threshold effects. What is important to note, it's the impossibility, for this tax, to charge tax credits. As for the exceptional contribution for high incomes for individuals, the logic is to prevent tax optimization for the “very rich” ! otherwise, an advance payment of 98% must be paid at the end of the year. French VSE-SMEs are not affected.
Joining an approved management center becomes irrelevant
Remember that membership in a CGA (approved management center) your AGA (approved management association) allowed VSEs to benefit from an income tax reduction of up to 915 euros, for bookkeeping and membership expenses to these organizations. This advantage is eliminated as of the 2025 income tax.
Planing of the research tax credit
The finance law for 2025 adjusts the research tax credit by removing the taking into account of a certain number of expenses. In particular, the possibility of doubling expenses linked to the first hiring of doctoral students during the first 24 months has been removed.. Second planing : so far, the flat rate for taking into account operating expenses was 43% of personnel expenses. This rate is lowered to 40%. And finally, certain expenses can no longer be taken into account, notably :
• All patent-related expenses : fees for taking out and maintaining patents, allocations to patent amortization, etc.
• Companies could allocate up to 60,000 euros in expenses related to technological monitoring ; this “envelope” has been removed. Uncertainty persists : the finance law having been passed on February 15, it is unclear whether these provisions apply from February 15, or for the whole year 2025. otherwise, the finance law for 2025 specifies the notion of “public subsidy” : This concerns all aid paid by legal entities under public law or by legal entities under private law entrusted with a public service mission..
Extension of the innovation tax credit
This tax credit was threatened, but it is finally extended by three years until December 31, 2027. This is good news for SMEs, even if it is also reduced in the sense that the rate of eligible expenses goes from 30 to 20%, and always within the limit of 400,000 euros from January 1, 2025.
Lowered thresholds for self-employed people
Self-employed people do not declare VAT, and don't collect it either, provided that they do not exceed a certain amount of turnover. These thresholds ranged from 36,800 to 101,000 euros depending on the nature of the activity. They are drastically reduced to a single ceiling of 25,000 euros, and without distinction of the nature of the activity carried out. Nearly 250,000 entrepreneurs are affected. France chooses to align with the European thresholds of 25,000 euros. Faced with the contestation that this measure has raised, it is suspended until June 1, 2025.
Adjustments to the simplified tax system for VAT
Until now, companies which chose this regime paid two installments during the year and a regularization in May of the following year. From 2027, we switch to a real regime. There will no longer be any notion of deposit. Depending on a threshold which will a priori be one million euros, either the company will have to make monthly declarations, like normal reality in fact, is, if it is below this threshold, it will have to make quarterly “real” declarations.
Fight against VAT fraud for traders
To combat VAT fraud, to prove that their cash register software was compliant, Until then, merchants could provide an individual certificate from the software publisher itself undertaking to comply with the model set by the administration.. The finance law removes the possibility of this individual certificate. From now on, publishers must obtain a certificate attesting that their software is compliant, and provide it to their merchant customers.
Contribution on added value of companies : the downward trajectory is slowed
In the government's logic of reducing production taxes, the abolition of the CVAE was scheduled for 2027, with a gradual downward trajectory. Given the state of public finances, on the one hand this deletion has been postponed for three years and will only be effective in 2030, on the other hand the 2025 rate will ultimately be identical to that of 2024 : 0,28 %. But this rate of 0,28% is not as simple as it seems... Indeed the rate initially voted for 2025 was 0,19 %. Technically, it could no longer be modified. To bring in tax, an additional tax for 2025 has been voted, equal to 47,4% of the CVAE due. Do the math : this amounts to a rate of 0,28 %. This small complexity will have an impact on the payment of this contribution. : a deposit will be due in June based on the initial rate of 0,19 %. And in September 2025, another deposit will be due based on the rate of 0,19% and another on the entire differential contribution. Be careful to calculate the amount due in September !
The criteria are tougher for young innovative companies (IF)
To be exempt from social contributions, JEIs must now devote 20% of their expenses to research and development, compared to 15% previously. These JEIs are companies created until 2024 and which could benefit from exemptions from the IS, on local taxes and social contributions. The finance law for 2024 had created a subcategory : young companies
growth (JEC), with a lower rate of research and development expenditure, between 5 and 20%, and at the same time less significant advantages : they can certainly benefit from exemption from local taxes and social security contributions., but not on profit tax. Consequently, JEIs which do not reach the rate of 20% will “fall back” into the status of JECs. These provisions are applicable from March 2025.
Taxation on the most polluting vehicles is increased
The aim is to encourage businesses to use cleaner vehicles. The finance law toughens the CO2 penalty and the weight penalty ; it introduces an incentive tax on company fleets and reforms the tax definition of utility vehicles and passenger vehicles.
