I: Income tax deducted at source

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Article 182 A bis

French General Tax CodeIn force

Updated 8 Nov 2023

I. - Sums paid, including salaries, in consideration for artistic services provided or used in France, by a debtor who carries on business in France to persons or companies, subject to income tax or corporation tax, who do not have a permanent place of business in that country, give rise to the application of a withholding tax.

II. - The basis for this deduction is the gross amount of the sums paid after deduction of a 10% allowance for professional expenses.

III. - The rate of deduction is set at 15%.

IV. - The withholding is deducted from the amount of income tax established under the conditions provided for in a of Article 197 A. For the application of this provision, the net taxable income used to calculate income tax is determined under the conditions of ordinary law.

V. - The provisions of the first paragraph of Article 197 B are applicable for the fraction of remuneration determined in accordance with II which does not annually exceed the upper limit set by III of Article 182 A.

VI. - The rate of withholding is increased to 75% for sums, other than salaries, paid to persons domiciled or established in a non-cooperative State or territory within the meaning of article 238-0 A other than those mentioned in 2° of 2 bis of the same article 238-0 A, unless the debtor provides proof that these sums correspond to actual transactions which mainly have a purpose and effect other than allowing them to be located in a non-cooperative State or territory. This withholding is in full discharge of income tax and is non-refundable.

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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