1: Direct taxes and assimilated taxes. Income tax. Corporation tax. Duties and penalties

Articles in this section · 8

Article 1663 bis

French General Tax CodeIn force

Updated 7 Nov 2023

When the taxpayer taxed under the conditions of 1 of article 202 becomes, within a period of three months from the date of cessation of activity, a partner in a liberal practice company mentioned in

Article 2

of Law no. 90-1258 of 31 December 1990 relating to the practice in the form of companies of the liberal professions subject to legislative or regulatory status or whose title is protected or a partner in a company referred to in articles 8 and 8 ter, carrying on a liberal profession, in order to practice his profession there, the payment of the tax corresponding to the acquired receivables referred to in the first paragraph of 1 of article 202 may, at the express and irrevocable request of the taxpayer, be split into equal parts, either over the year of cessation and the two following years, or over the year of cessation and the four following years. The split gives rise to the payment of interest, at the legal rate, recovered under the same conditions and subject to the same guarantees and penalties as the principal tax.

These provisions also apply when a company mentioned in

articles 8

and

8 ter

, engaged in a liberal profession, ceases to be subject to the regime provided for by these articles as a result of an option for the regime applicable to limited companies exercised under the conditions provided for in 1 of

Article 239.

In the event of transfer of domicile outside France, death, withdrawal of the partner from the company or non-payment of one of the fractions of the tax, the balance remaining due, plus accrued interest, is payable immediately.

Mariela Petrova

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Common Questions

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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