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2020 draft French budget includes ATAD II and corporate tax rate provisions

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October 2019


The French government on September 27 released its draft budget for fiscal year 2020 (‘the draft budget’). The draft budget includes corporate tax measures designed to transpose into French law Articles 9, 9 bis, and 9 ter of EU anti-tax-avoidance directive 2016/1164 dated July 12, 2016 (ATAD I) as modified by EU directive 2017/952 dated May 29, 2017 (ATAD II).  The document also includes other EU-compliant measures and proposes to postpone, for large companies, the scheduled reduction of the corporate income tax rate.

The takeaway

MNEs operating in France should consider the impact of the draft budget with respect to their international flows, structure, and tax obligations. Enactment of such proposed provisions could occur by the end of December 2019.

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Doug McHoney

International Tax Services Co-Leader, PwC US

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