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France Clarifies Offset of Foreign Tax Credits in Relation to 3.3% Social Surcharge

|Approved Changes|France
France

The French tax authority has announced an update to guidance on the payment of the 3.3% social contribution surcharge that is levied on corporate income tax exceeding EUR 763,000 per year. The update concerns foreign tax credits, including that companies benefiting from foreign tax credits are free to determine the order of imputation of the credit against corporate income tax and the surcharge. In this respect, the guidance explains that although Article 235 ter ZC of the Tax Code restrict…

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