The French tax authorities have updated their guidelines of the new rules regarding carry forward losses arising from the Finance Bill for 2013 (Article 24 of Law n°2012-1509 dated 29 December 2012). As a reminder, the allocation of prior losses on the current taxable income recognized in a given year is only possible up to a ceiling of € 1 million plus an amount of 50% beyond, for financial years ending on or after 31 December 2012 (against 60% previously).

The French tax authorities have also specified that the beneficiary companies of a debt waiver pursuant to a reached or approved agreement under a safeguard or liquidation process, are allowed to increase the limit of 1 million euros by the amount of this waiver (BOI-IS-DEF-10-30-20130410 dated 10 April 2013).