The French tax authorities have published their final comments of the overall capping of the deductibility of net financial expenses of companies, established by the Finance Act 2013 (article 23 Law n°2012-1509 dated 29 December 2012 – in particular BOI-IS-BASE-35-40-20130806 dated 6 August 201-3).

As a reminder, companies subject to corporate tax which have an amount of net financial expenses of at least € 3 million can deduct only 85% of these costs in determining the results for the years ended as of 31 December 2012 and 75% for fiscal years beginning on or after 1 January 2014 (article 212 bis of the French Tax Code).