Extension of the favourable tax regime of provisions
Article 62 of the Law no. 94-1-162 dated December 29, 1994 has extended the regime of provisions for setting up of services abroad, applicable upon agreement, to companies subject to corporate income tax carrying on a professional non commercial activity and which set up a company of a subsidiary of which the exclusive object is the exercise of this activity.
In addition, the investment ceiling giving right to provisions has been increased from MF 10 to MF 20 for all settings up of services, commercial or not.
Moreover, Article 19 of the law no. 95-95 dated February 1st, 1995 has extended the regime of provisions for industrial settings up to French companies which realize an agricultural investment in a non E.C. member country.
In a directive dated July 24, 1995 (published in the B.O. dated August 9), the Tax Authorities make comments on these modifications and specify the case of settings-up carrying on mixed activities giving right to provisions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be brought about your specific circumstances. For additional information contact Claire Acard on 33/(1)/42.91.07.00 or Lionel Benant on 33/78.63.72.35 or enter text search: "ARCHIBALD ANDERSEN Profile". The members of ARCHIBALD ANDERSEN Association d'Avocats (S.G. Archibald and Arthur Andersen International) are registered with the Hauts-de-Seine Bar and the Lyon Bar.
