A company may be incorporated in another EU country, for example Ireland, while its directors work from France. On paper everything happens abroad. In practice, decisions are made in Paris, Lyon or Nantes. With remote work this situation is increasingly common, and it raises a tax question: is the company liable to French corporate income tax (CIT), and how does it get registered?
This article sets out the essentials. It complements our page on corporate tax registration in France.
A foreign company managed from France
Corporate income tax is a tax on profits. In France it applies in principle to the profits of businesses operated in France. A company incorporated abroad is therefore not taxable in France merely because one of its directors lives there. The question arises when the business is actually carried on from France: decisions made on the spot, a team, an office, contracts negotiated and signed from French territory.
Connection to France: what is examined
The analysis rests on several criteria that are combined. Tax treaties between France and the company’s country of incorporation can change the outcome. Several of them look at the place where the company is effectively managed, for example.
| Element | What is looked at |
|---|---|
| Management | Where strategic and day-to-day decisions are made, and by whom. |
| Team | Where directors and employees work, and under what arrangement. |
| Resources | Office, premises or equipment used in France on a habitual basis. |
| Contracts | Where they are negotiated, signed and performed. |
| Tax treaty | The definition of residence and permanent establishment that applies between the two countries. |
This analysis is close to that of a permanent establishment. It is done before any formality, because tax registration in France has lasting consequences: returns, instalments, audits.
The registration formality
There is no standalone procedure called “CIT registration”. The business makes itself known to the tax authorities through an online formality on the business formalities one-stop shop (guichet unique). The file is passed on, in particular, to INSEE, which issues the SIREN and SIRET numbers, and to the competent business tax office (SIE), which opens the tax file.
The exact list of documents depends on the situation: the one-stop shop gives the final list. Documents drawn up abroad may need a translation.
After registration: returns and instalments
| Obligation | What to know |
|---|---|
| Results return | Form 2065-SD and tax return package, filed electronically, within three months of the year-end, or by the second working day after 1 May for a financial year ending on 31 December. |
| Instalments | Four instalments: 15 March, 15 June, 15 September and 15 December, based on the previous year’s CIT. No instalment if that CIT is below €3,000. |
| Balance | By the 15th of the fourth month after the year-end: 15 May for a year ending on 31 December. |
The standard CIT rate is 25%. A reduced 15% rate exists, under conditions, on part of the profits of certain small companies. The first financial year follows special rules, notably for instalments, to be checked case by case. See the official page Imposition des résultats (in French).
Accounts and tax return package
The results return relies on annual accounts drawn up under French rules. Preparing them and the tax return package is, as a general rule, a chartered accountant’s job. Hanoutax does not keep the books: we coordinate with your accountant, or introduce you to one.
What about VAT, CFE and other taxes?
CIT is only one part. Depending on the business, other obligations may apply: VAT registration at the first taxable transaction, CFE, and payroll tax where the activity gives rise to it. A grant, for example, is in principle outside the scope of VAT: it all depends on the nature of the transactions.
How Hanoutax can help
Hanoutax acts as a tax agent under a written mandate, not as a fiscal representative. We can prepare the preliminary analysis, follow the registration formality, set up your tax account and the calendar of deadlines, then follow your notices. Nothing is filed without your written consent. For a first approach, use our quick check.
Frequently asked questions
Is an Irish company managed from France subject to CIT in France?
It depends on its connection to France and on the treaty between France and Ireland. If the business is actually carried on from France, the company may be taxable there. The analysis is made on the facts, before any formality.
Where is the registration made?
Online, on the business formalities one-stop shop, which passes the file to INSEE and to the business tax office.
Do I need to wait for revenue before acting?
No. The obligation to make yourself known arises from carrying on the business in France, not from the first receipt. It is better to analyse your situation at the start than after an audit.
Does Hanoutax prepare the accounts and the tax return package?
No. This work is, as a general rule, a chartered accountant’s. We work alongside them.
Does CIT registration mean VAT registration too?
Not automatically. VAT registration depends on the transactions carried out: it becomes necessary at the first taxable transaction in France.
Is your company run from France?
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Informational content, not legal advice. The applicable rules depend on your situation.
