2°: Payment of tax

Articles in this section · 2

Article 223 O

French General Tax CodeIn force

Updated 8 Nov 2023

1. The parent company is substituted for the companies in the group for the purposes of setting off against the amount of corporation tax for which it is liable in respect of each financial year:

a. Tax credits attached to income received by a group company and which did not give entitlement to the application of the parent company regime referred to in Articles 145 and 216 ;

b. Tax credits for research expenditure generated by each company in the group pursuant to article 244 quater B ; article 199 ter B applies to the sum of these tax credits;

b bis. Tax credits for collaborative research generated by each company in the group pursuant to Article 244 quater B bis; Article 199 ter B bis applies to the sum of these tax credits;

c. Tax credits generated by each company in the group pursuant to article 244 quater C; article 199 ter C applies to the sum of these tax credits;

d. The investment tax credits generated by each company in the group pursuant to Article 244 quater E; the provisions of Article 199 ter D apply to the sum of these tax credits;

e. Tax reductions generated by each company in the group pursuant to article 238 bis ;

f. The tax credits generated by each company in the group pursuant to Article 244 quater F ; the provisions of Article 199 ter E apply to the sum of these tax credits;

g. The tax credits generated by each company in the group pursuant to Article 220 sexies ; the provisions of Article 220 F apply to the sum of these tax credits;

h. Tax reductions generated by each company in the group pursuant to Article 220 undecies;

i. (Repealed);

j. Tax credits generated by each company in the group in application of article 220 sexies A; the provisions of article 220 F bis apply to the sum of these tax credits;

k. Tax credits generated by each company in the group pursuant to article 244 quater J ; the provisions of article 220 K apply to the sum of these tax credits;

l. (Expired);

m. Tax credits generated by each company in the group pursuant to article 244 quater M; the provisions of article 199 ter L apply to the sum of these tax credits;

n. Tax credits generated by each company in the group pursuant to Article 244 quater L; the provisions of Article 220 M apply to the sum of these credits;

o. (Expired);

p. Tax credits generated by each company in the group pursuant to article 244 quater O; the provisions of article 220 P apply to the sum of these tax credits;

q. The tax credits generated by each company in the group pursuant to article 220 octies ; the provisions of article 220 Q apply to the sum of these tax credits;

r. Of the tax credits generated by each company in the group pursuant to article 220 nonies, the provisions of article 220 R apply to the sum of these tax credits;

s. Tax credits generated by each company in the group pursuant to article 220 quindecies; article 220 S applies to the sum of these tax credits;

t. Tax reductions generated by each company in the group pursuant to article 220 undecies A;

u. (Repealed)

v. Tax credits generated by each company in the group pursuant to article 220 sexdecies; article 220 T applies to the sum of these tax credits;

w. Tax credits generated by each company in the group pursuant to article 220 terdecies ;

x. Tax credits generated by each company in the group pursuant to article 220 septdecies; article 220 Q bis applies to the sum of these tax credits;

y. Tax credits generated by each company in the group pursuant to article 244 quater U ; article 220 Z applies to the sum of these tax credits;

z. The tax credits generated by each company in the group pursuant to Article 220 quaterdecies ; the provisions of article 220 Z bis apply to the sum of tax credits;

z bis. Tax credits generated by each company in the group pursuant to article 244 quater V ; the provisions of article 220 Z ter apply to the sum of these tax credits;

z ter. Tax credits generated by each company in the group pursuant to article 244 quater W; article 220 Z quater apply to the sum of these tax credits;

z quater. Tax credits generated by each company in the group pursuant to Article 244 quater X; Article 220 Z quinquies applies to the sum of these tax credits;

z quinquies. Tax reductions generated by each company in the group pursuant to article 244 quater Y; article 220 Z sexies applies to the sum of these tax reductions.

2. (Repealed).

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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