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May 2020 - Volume 3 No. 2
Extraordinary French Tax Relief Measures For Enterprises
By Arnaud Jouanjan and Christophe Jolk
Rödl & Partner Avocats (France)

Tax Measures

The French President, Mr. Emmanuel Macron, has installed a general confinement of the French population as of noon on 17 March 2020, due to the most recent and very concerning evolutions of the spread of COVID-19 in France.

The French government and particularly the French tax authorities have already started to put in place extraordinary measures to relieve French or foreign enterprises which might be taxable in France.

As such, it is possible for enterprises to request from their respective competent French tax bureaus the postponement without penalties of their next payable direct taxes or their advance payments (such as the French corporate tax for instance). If advance payments have already been initiated in March, enterprises may try to oppose their executions directly with their banks. Or, if the payments have already been completed, enterprises may request a refund with their respective French tax bureaus.

To simplify such requests, enterprises may use the new and special forms provided on the website of the French tax authorities1. In case of any difficulties to pay their taxes, enterprises should not hesitate to contact their respective tax bureaus via their specific and secured taxpayer accounts, via e-mail or telephone.

Due to the current COVID-19 pandemic, the French 2019 income tax declaration online services will open on 20 April 2020, instead of the originally set date of 9 April 2020. Pre-filled tax forms will be sent between 20 April and mid-May and only to taxpayers who sent paper tax declarations last year.

Further, all declarations deadlines have been pushed back to the following dates:

  • Nonresidents and individuals residing in French departments 1 through 19: Thursday 4 June 2020, 11:59 pm
  • Individuals residing in French departments 20 through 54 (including 2A and 2B): Monday 8 June 2020, 11:59 pm
  • Individuals residing in French departments 55 through 974/976: Thursday 11 June 2020, 11:59 pm
  • Paper filing (only if no internet connection is available or if filing online is not possible otherwise), including nonresidents: Friday 12 June 2020, 11:59 pm.

Declaration deadlines for companies have also been postponed to 30 June  2020. This notably applies to corporate income tax returns, with the exception of multinational enterprises with the exception of M.N.E.s unless they undertake to forego the declaration and distribution of dividends in 2020, and to real estate companies not subject to corporate income tax.

French tax authorities have also stated that a forced stay on French soil due to travel bans will likely be disregarded for determining where one has a "home" or a “residence” for tax purposes.

Relief Measures

The French Government has taken several far-reaching emergency measures to help businesses through the current health crisis.

The Government will guarantee business short-term loans up to €300 billion to avoid bankruptcy. These loans will be guaranteed by the State up to 90% of the principal and interests. They concern most businesses.

Loan application are to be made directly to your banks.

Tax measures have also been taken. A 3-month postponement of all tax and social charges deadlines can be requested without any justification - but V.A.T. is still due. It is also possible to apply for direct tax reliefs. Applications will be examined on a case-by-case basis.

Please find hereafter the other measures taken as of today:

  • Stability of employment through partial unemployment schemes made simpler and covered by the State.
  • Immediate financial support of €1,500 for small and micro-businesses and self-employed workers.
  • Postponement of rents and water, gas and electricity bills for small ailing businesses.
  • Deferred repayment of bank loans is made easier.
  • The emergency fund for small businesses has been increased to a total of €7 billion. In addition to the €1,500 support mentioned above, financial support of €2,000 to €5,000 can be allocated to small businesses.
  • Companies with pending V.A.T. and corporate income tax credits can apply for an immediate refund.

1 https://www.impots.gouv.fr/portail/node/13465
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