4c: Partial deductibility of the general social contribution

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Article 154 quinquies

French General Tax CodeIn force

Updated 8 Nov 2023

I. - For the determination of income tax bases, the contribution provided for in article L. 136-1 of the Social Security Code in respect of earned income and replacement income or that relating to the income mentioned in 4° of I of Article L. 136-7 of the aforementioned Code is, up to 6.8 points or, for the income mentioned in II of l'article L. 136-8 of the same code, up to 3.8 points where it is levied at the rate of 3.8% or 6.2%, up to 4.2 points where it is levied at the rate of 6.6% and up to 5.9 points where it is levied at the rate of 8.3%, deducted from the gross amount of the sums paid and the benefits in kind or in money granted, or from the taxable profit, in respect of which the contribution was paid. The contribution due on the benefit mentioned in I of article 80 bis as well as on the benefit mentioned in I of article 80 quaterdecies when the latter is subject to income tax according to the rules of common law for salaries and wages is allowed as a deduction from the taxable income of the year of its payment.

II. - The contribution relating to the income mentioned in a to e and f of I and II of article L. 136-6 of the Social Security Code and the first paragraph and 1° of I of Article L. 136-7 of the same code, imposed under the conditions provided for in Article 197 of this code, is allowed as a deduction from taxable income for the year in which it is paid, up to a maximum of 6.8 points.

The contribution is deductible, under the conditions and for the portion defined in the first paragraph of this II, up to the ratio between the amount of income subject to income tax and the amount of that same income subject to the contribution for:

a) The gains mentioned in Article 150-0 A which benefit from the allowance provided for in 1c of Article 150-0 D or the fixed allowance provided for in 1 of I of article 150-0 D ter ;

b) The salary benefits referred to in I of Article 80 quaterdecies which benefit from the allowances provided for in 1 ter or 1 quater of article 150-0 D, as it stood prior to 1 January 2018, the fixed allowance provided for in 1 of I of article 150-0 D ter or the 50% allowance provided for in 3 of article 200 A.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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