France budget rejection leaves large-company surtax extension unresolved

The recorded vote was 458 against, none in favour and two abstentions. Under Article 119(3) of the Assembly’s Rules, failure to adopt the first part means the bill is treated as rejected at first reading. This is a legislative-stage development, not a change to current French tax law.^[1][2]

What Article 15 had proposed

Government Bill no. 3210 would have amended Article 48 of the 2025 Finance Act to extend the exceptional contribution from two to three financial years. For the proposed third year, Article 15 retained a €1.5 billion turnover threshold and specified rates of 15.7% and 31.4% for the two rate bands. It also proposed restoring for one year the separate contribution on operating profits of large maritime transport companies under Article 50.^[3]

Existing rules continue

The rejected extensions have no effective date. Existing law still applies to the first two financial years closing on or after 31 December 2025. For the second year, the threshold is €1.5 billion. Official guidance attributes turnover by reference to profits taxed in France and applies group aggregation rules to the parent of a French tax-consolidated group. Calendar-year companies that fall within the existing measure should continue to assess the 98% advance payment due with the final corporation-tax instalment on 15 December 2026.^[4][5]

Multinational groups should not recognise the proposed third-year charge as current law. French companies, branches and tax-consolidated groups should nevertheless preserve their French-taxable turnover, group and year-end analysis for the rules already in force, and monitor any replacement or revived 2027 budget measure. The Senate dossier records the Assembly rejection and, as updated on 6 November, does not show a subsequent Senate reading. The official records reviewed do not establish what budget route or final tax measures will follow.^[4][5][6]