France: Certain proposed tax measures in 2027 Finance Bill adopted by Finance Committee, including change to Pillar Two threshold

The Finance Committee on October 2, 2026, generally rejected the text of the revenue section of the French 2027 Finance Bill, but adopted without change the proposed additional one-year extension of the exceptional surtax on corporate income tax applicable to largest companies with significant profits.

The Finance Committee also adopted the following new proposed tax measures:

• Increase in the share of costs and expenses added back to the tax base for capital gains on the sale of equity investments
• Adjustments to the research tax credit (CIR)
• Change to the threshold for the global minimum tax
• Repeal of tax on share buybacks, replaced by a 10% registration duty on such transactions
• Expansion of temporary “Industry 4.0” super-depreciation scheme for small and medium-sized enterprises (SMEs) and mid-cap companies to investments in software and cybersecurity equipment

Given the lack of a clear majority in the National Assembly, it remains difficult to predict which amendments will ultimately be adopted during the public session. The amendments adopted by the Finance Committee are expected to be presented again during the plenary session, and others may also be considered.

Among the approximately 3,900 amendments tabled for the plenary session, two come from the government: one aims to repeal provisions requiring financial offsets that were not lifted in certain laws passed in 2026, while the other seeks to adjust certain implementation details of the global minimum tax (specifically transposing certain safeguard measures, including the "Side-by-Side" mechanism).

Deputies will begin examining the text in the plenary session on October 13, 2026, provided the motion for preliminary rejection tabled by the Socialist group is defeated.

Read an October 2026 report (French) prepared by KPMG Avocats