France: Tax-related provisions in finance law for 2024

Pillar Two rules and transfer pricing documentation changes

Pillar Two rules and transfer pricing documentation changes

The French Finance Act (FFA) for 2024 was adopted on 21 December 2023 by the French Parliament and became effective after being published to the official gazette. The most significant measures affecting companies include:

  • The implementation of the EU Directive on Pillar Two into domestic law
  • The adjustment of the time table for phasing out the contribution on companies’ added value (cotisation sur la valeur ajoutée des entreprises—CVAE) between 2024 and 2027
  • The introduction of a new tax credit for investments in “green industries”
  • The alignment of the parent-subsidiary regime with EU law
  • The implementation of several measures strengthening transfer pricing documentation requirements

Read a January 2024 report [PDF 197 KB] prepared by the KPMG member firm in France



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