The French tax authorities have commented the change of the last corporate income tax instalment regime applicable to large companies and members of a tax group, and the thresholds triggering penalties, as introduced by the Finance Act 2013 (article 26 of Law n° 2012-1509 dated 29 December 2012) (BOI-IS-GPE-30-30-10-20130611 dated 11 June 2013).

Companies concerned by the requirement to calculate the last corporate income tax instalment by reference to the estimated profits (instead of the taxable income of last financial year for the other companies) are companies with a turnover of € 250 million (against € 500 million previously). Moreover, the percentage of the amount of the estimated corporate income tax for the calculation of the final instalment is paid to:

  • 75% (instead of 66.2/3%) for companies whose turnover is between € 250 million and € 1 billion;
  • 85% (instead of 80%) for companies whose turnover is between € 1 billion and € 5 billion;
  • 95% (instead of 90%) for companies whose turnover exceeds € 5 billion.

These amendments apply to fiscal years beginning on or after 1 January 2013.