Corporate taxation : France vs United States — A comparative analysis for businesses

france vs united states

Understanding the differences in tax structures between France and the United States is essential for businesses operating internationally. Both countries offer unique advantages and challenges due to their distinctive tax policies. This article explores the corporate tax environment in both France and the United States, offering a detailed comparison to help businesses make informed decisions.



1. How do corporate tax rates in France compare to those in the United States?


Tax rates are often the most immediate consideration for businesses when assessing the tax environments of different countries. Both France and the United States have undergone significant tax reforms in recent years aimed at attracting and retaining businesses.


a. Current corporate tax rates

As of the latest updates, France has set its standard corporate tax rate at 28%, with a commitment to reduce it to 25% by 2022 to align more closely with the European average. In contrast, following the Tax Cuts and Jobs Act of 2017, the United States set its federal corporate tax rate at a flat 21%, significantly lower than France’s current rate.


b. Treatment of small to medium enterprises (SMEs)

France offers a reduced tax rate for smaller businesses, known as the “réduit rate,” which applies to the first €500,000 of profits, aiming to support SMEs’ growth and sustainability. The United States also offers various deductions and credits designed to benefit small businesses, though the federal tax rate remains the same across all business sizes.


c. Long-term planning considerations

While the lower tax rate in the United States may seem attractive initially, France’s system of credits and deductions, particularly for research and development, can result in a lower effective tax rate for companies engaged in innovation-driven industries.



2. What are the key differences in deductions and credits offered?


Beyond basic tax rates, deductions and tax credits are crucial factors that can significantly impact a company’s final tax liability. Both France and the United States offer a range of tax incentives designed to spur economic activity and support specific industries.


a. Research and development incentives

The French government offers the Crédit d’Impôt Recherche (CIR), a tax credit that allows companies to deduct up to 30% of their R&D expenses. This is one of the most generous R&D tax incentives globally. Conversely, the U.S. offers the Research and Development Tax Credit, which is less generous than France’s but still provides significant savings, particularly after recent enhancements.


b. Depreciation and capital allowances

Both countries allow businesses to write off capital expenditures, though the methods and rates differ. The U.S. tax reform introduced provisions for full expensing of certain types of capital investment for a limited time, whereas France typically uses a system of depreciation over the asset’s useful life.


c. Tax credits for international trade

The United States provides several credits and deductions aimed at encouraging international trade, including the Foreign-Derived Intangible Income (FDII) deduction and the Foreign Tax Credit. France also provides mechanisms to avoid double taxation for companies operating internationally, ensuring that global profits are not excessively taxed.



3. How do tax treatments of losses differ between France and the United States?


The ability to carry forward or back losses can influence business planning and investment decisions, particularly in industries prone to cyclical fluctuations.


a. Loss carryforward and carryback Policies

In France, tax losses can be carried forward indefinitely, but the carryback option is limited to one year, with a cap of €1 million. The United States, following recent tax reforms, allows losses to be carried forward indefinitely without expiration, but the carryback of losses has been eliminated except for specific circumstances.


b. Impact on business strategy

These policies impact how businesses plan for and manage fluctuations in profitability. U.S. businesses may find the indefinite carryforward beneficial for long-term planning, while French businesses benefit from the immediate relief provided by the carryback option, albeit limited.




When comparing the business tax environments of France and the United States, companies must consider more than just the headline corporate tax rates. Tax credits, deductions, and specific incentives related to industry and activities play a significant role in determining the overall tax burden. While the U.S. offers a lower corporate tax rate, France’s generous R&D credits and specific incentives for SMEs can be highly attractive for businesses in certain sectors. Ultimately, the decision on where to operate should take into account the full scope of each country’s tax regime, tailored to the strategic needs of the business.

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