French General Tax Code
In forceI. - In limited liability companies that have not opted for the partnership tax regime under the conditions provided for in IV of Article 3 of Decree no. 55-594 of 20 May 1955 as amended and whose managers have a majority shareholding, in partnerships limited by shares, as well as in limited partnerships, general partnerships, joint ventures and civil partnerships that have exercised the option provided for in Article 206 3, salaries, fixed expense reimbursements and any other remuneration are, subject to the provisions of 3 of Article 39 and 211 bis, allowed as a deduction from the company's profit for tax purposes, provided that such remuneration corresponds to actual work.
Sums deducted from the company's profit under the first paragraph are subject to income tax in the name of the beneficiaries under the conditions set out in Article 62.
For the application of this article, managers who do not personally own shares in the company are considered to be partners if their spouse or unemancipated children are partners.
In this case, as in the case where the manager is a partner, shares owned outright or in usufruct by the manager's spouse and unemancipated children are considered to be owned by the manager.
II. - The provisions of I are not applicable:
a. (Expired).
b. To co-ownership property companies referred to in article 1655 ter.
c. To limited liability companies that have opted for the tax regime provided for in Article 239 bis AA or that provided for in Article 239 bis AB.
