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France - Reform of the French IP Regime: Overview of Conditions and Opportunities

C. Silberztein; R. Bricard
International Transfer Pricing Journal, 2019 (Volume 26), No 3
9 May 2019
The French tax regime for IP income was deeply modified by the 2019 Finance Act in order to comply with the latest OECD and EU standards on harmful tax regimes. The new French IP regime is more restrictive in that it introduces the Nexus rule, is applicable to net rather than gross income, and generally excludes patentable inventions from the list of eligible assets (except for SMEs). It however presents several new opportunities, including a reduced 10% tax rate and an extension of its scope, under relevant conditions, to software income. An assessment of the possible benefits from the regime is recommended, primarily for tech companies of course, but also for other businesses, e.g. for the many non-tech groups which centrally develop software for use by affiliates throughout the world.
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