I: Income tax deducted at source

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Article 182 A

French General Tax CodeIn force

Updated 8 Nov 2023

I. With the exception of salaries falling within the scope of article 182 A bis, French-source salaries, wages, pensions and life annuities paid to persons who are not domiciled in France for tax purposes give rise to the application of a withholding tax.

II. The basis for this withholding is the net amount of the sums paid, determined in accordance with the rules applicable to income tax, excluding those which provide for the deduction of actual professional expenses.

III.-The withholding is calculated, according to a rate corresponding to a period of one year, by applying to the fraction of the sums subject to withholding which exceeds €16,050 the rate of:


a) 12% for the portion in excess of €16,050 and up to €46,557;


>> b) 20% for the portion in excess of €16,050 and up to €46,557; and b) 20% for the portion in excess of €46,557;


The rates of 12% and 20% mentioned in a and b of this III are reduced to 8% and 14.4% respectively in the overseas departments. When the sums subject to deduction are paid on a quarterly, monthly, weekly or daily basis, the limits of the brackets of the annual tariff provided for in this III are divided by 4, 12, 52 or 312 respectively.

IV.-Each of the limits of the brackets of the tariff provided for in III is revised each year in the same proportion as the upper limit of the first bracket of the income tax scale. The amounts obtained are rounded to the nearest euro; the fraction of a euro equal to 0.5 is counted as 1.

V. The withholding is deducted from the amount of income tax established under the conditions provided for in Article 197 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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