France: Tax measures in Finance Act 2025

Includes update of Pillar Two rules

The French Finance Act for 2025 was adopted by the Parliament on February 6, 2025, and will become formally enacted after publication in the official gazette.

The most significant tax-related measures affecting companies include:

Introduction of an exceptional surtax on corporate income tax applicable to the largest companies with significant profits
New adjustment of the phasing out the contribution on companies’ added value (cotisation sur la valeur ajoutée des entreprises (CVAE))
Tax on share buy-backs
Introduction of a beneficial ownership condition in the French tax Code for withholding tax on dividends
Update of Pillar Two rules to implement OECD guidance from December 2023
0.1% increase in the financial transaction tax rate (from 0.3 to 0.4%)

Read a February 2025 report prepared by KPMG Avocats

Read a February 2025 report prepared by KPMG’s EU Tax Centre that describes the updates to the Pillar Two rules

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France: Tax measures in Finance Act 2025

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