In the night of 27 to 28 October 2026, the French National Assembly adopted, by 74 votes to 72, an amendment to the 2027 finance bill that would change how foreign groups are taxed in France. Taxable profit would no longer be the profit declared by the French companies, but a share of the group’s worldwide profit, calculated on the basis of the turnover generated in France. The government opposed it, and the measure is unlikely to make it into the final finance act.
What the amendment provides
Amendment no. I-3945, tabled by Nicolas Sansu (Gauche démocrate et républicaine group), would create a new article 209-0 A bis of the CGI. It targets groups whose parent company is based outside France and whose total turnover exceeds €100 million.
- taxable profit in France would be the share of group turnover generated in France, applied to the group’s overall profit
- one group company, chosen by the group or designated by the tax administration, would alone owe the corporate income tax (“impôt sur les sociétés”) due in France by the whole group
- for each country where the group operates, the companies concerned would report their locations, type of activity, turnover and profit before tax
- in case of refusal, the text provides for a ban on operating in France
The rule would take effect on 1 January 2027. The government would also have to report to Parliament within three months on which tax treaties need renegotiating to avoid double taxation.
A highly uncertain measure
The budget’s general rapporteur, Philippe Juvin, opposed the amendment, arguing that tax treaties only allow France to tax companies located in France. Economy minister Roland Lescure called it “a very bad idea”.
An adopted amendment is not yet law. On 4 November, the Assembly was still debating the first part of the finance bill, which covers revenue. If that part is rejected, the government’s original text, without the amendments adopted so far, goes to the Senate. For final adoption, the government could use article 49.3 of the Constitution and keep the amendments of its choice.
What it would mean for a German group
Today, the French subsidiary of a German group is taxed on its own profit, which depends on transfer pricing. Under the rule voted, the turnover generated in France would set the share of group profit taxed in France, whatever the subsidiary earns. For a high-volume, low-margin distribution subsidiary, the tax base could rise sharply. And until tax treaties are adapted, the risk of double taxation would remain, as the text itself acknowledges.
Nothing has been decided yet. We are following the budget procedure and will come back to the subject if the measure makes it into the finance act. Transfer pricing and cross-border advisory
Sources: Assemblée nationale, amendment no. I-3945 to the finance bill for 2027 (no. 3210), adopted on 27 October 2026; LCP, 28 October and 3 November 2026. Updated 4 November 2026.