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France: Tax measures in Finance Act 2026 include extension of windfall tax on large companies, amendments to Pillar Two rules

Adopted by Parliament on February 2, 2026

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February 5, 2026

The Finance Act for 2026 was adopted by the Parliament on February 2, 2026, and will become formally enacted after publication in the official gazette.

The most significant tax-related measures affecting companies include:

  • One-year extension of the exceptional surtax on corporate income tax applicable to the largest companies with significant profits (its rate will not be halved, as was initially proposed, but its threshold will be increased for 2026 to €1.5 billion)
  • Introduction of tax on certain extravagant non-professional assets of holding companies (note that this was initially intended as a tax on the financial assets of asset holding companies)
  • Integration of OECD's Pillar Two June 2024 administrative guidelines and transposition of Council Directive (EU) 2025/872 on administrative cooperation to establish a framework for the exchange of Pillar Two information between member states (DAC9)

Read a February 2026 report prepared by KPMG Avocats

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