This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors.
France’s 2027 draft finance bill was released on 1 October 2026. Parliamentary discussions should begin on 13 October and are expected to be finalized by the end of December 2026 with a vote and enactment.
The discussion below summarizes the bill’s main tax proposals for companies.
Extension of the exceptional temporary surtax on corporate income tax
The standard corporate income tax rate would remain at 25%; however, the previous exceptional temporary surtax on corporate income tax would be extended for one additional fiscal year (FY), already having been extended for FY 2026.
As a reminder, the 2025 finance law introduced a temporary exceptional surtax on corporate income tax liabilities for very large companies (i.e., companies whose annual turnover, in France, is at least EUR 1 billion for the FY for which the surtax is due or for the previous FY).
The temporary exceptional surtax is calculated on the average of the corporate income tax due for the FY for which the contribution is due and for the previous FY, based on taxable income subject to the standard tax rate of 25%, as well as the reduced 10% rate applicable to patent box income. Depending on the company’s turnover, the temporary exceptional surtax applies at a rate of 20.6% or 41.2%.
The temporary exceptional surtax was supposed to apply only for the first FY ending on or after 31 December 2025. The 2026 finance law extended its application to the second FY ending on or after 31 December 2025. For the second year of application, however, the annual turnover threshold was raised from EUR 1 billion to EUR 1.5 billion. The method of computation and applicable rates remained unchanged.
The 2027 draft finance bill would extend the application of the surtax to the third FY ending on or after 31 December 2025.
The surtax rates would be reduced for the third year of application, as follows:
- 15.7% surtax: For companies with a turnover below EUR 3 billion for the FY for which the surtax is due and for the previous FY. The effective tax rate would thus rise to 29.75% as the standard rate; and
- 31.4% surtax: For companies with a turnover equal to or greater than EUR 3 billion for the FY for which the surtax is due or for the previous FY. The effective tax rate would thus rise to 33.68% as the standard rate.
Extension of the exceptional temporary tax for large shipping companies
Subject to certain conditions, shipping companies can elect to be subject to tonnage tax instead of corporate income tax.
The 2025 finance law introduced a temporary surtax on the operating income of shipping companies that elect the tonnage tax and whose turnover is at least equal to EUR 1 billion for the first FY ending on or after 31 December 2025. The applicable rate was 12%.
The 2027 draft finance bill would extend the application of the exceptional temporary tax for large shipping companies for the second FY ending on or after 31 December 2025. The applicable rate would be reduced to 8%.
Increase of tax rate on the exploitation of long-distance transport infrastructures
The 2024 finance law introduced a tax on the exploitation of long-distance transport infrastructures such as airports and highways (mainly large airports and large highway construction/maintenance companies; urban transport is excluded).
The tax is subject to a turnover threshold and a profitability threshold and applies if:
- The operating income for a given calendar year is greater than EUR 120 million; and
- The average level of operating profitability (net income to turnover ratio) is greater than 10%.
If both these thresholds are exceeded, the portion of operating income above EUR 120 million is subject to a 4.6% tax rate.
The 2027 draft finance bill would introduce a progressive increase in the applicable rate based on the average level of operating profitability. The rate would then range from 4.6% to 12.2%.
Expansion of the scope of the “tax credit for investment in green industries” (crédit d’impôt au titre des investissements en faveur de l’industrie verte, C3IV)
As a reminder, the 2024 finance law introduced a tax credit to boost investment in the green industry sector.
The C3IV is only granted, subject to prior approval by the minister in charge of the budget, for certain specific investments, such as investments in the production of batteries, photovoltaic panels, wind turbines, and heat pumps.
It is only available to industrial and commercial enterprises meeting specific criteria, for projects approved through 31 December 2028.
Depending on the location of the investment, the rate of the tax credit ranges between 15% and 35% of the investment. These rates are increased by 10 percentage points (i.e., between 25% and 45%) for investments made by medium-sized enterprises and by 20 percentage points (i.e., between 35% and 55 %) for investments made by small enterprises.
The 2027 finance bill would expand the scope of the C3IV to electricity networks, the solar thermal sector, electric vehicle battery packs, and permanent magnets used in electric propulsion technologies.
Exceptional accelerated depreciation regime
A special regime would be introduced for certain investments made between 1 January 2027 and 31 December 2029 to support the robotization and modernization of the industrial base of small and medium-sized enterprises in the industrial sector. This exceptional depreciation regime would allow qualifying assets to be depreciable at a rate ranging between 40% and 120%.
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