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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: France: Underlying Tax

(1) Documents needed to support the underlying tax claim

For all companies:

The following extracts from the tax return:

Page 2051 - balance sheet

Page 2053 - profit & loss account

Page 2058A - tax computation

Page 2058C (from the succeeding year’s tax return) -

appropriation of profits

For S803A ICTA 1988 tax consolidations:

The consolidated tax assessment (situation recapitulative)

A schedule detailing total accounts profits and losses

(French consolidations do not produce consolidated accounts)

For pre S803(A) 1988 ICTA tax consolidations:

Page 2058 TS - detailing taxable profits and losses

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(2) Reserves

Relevant profits are reduced by transfers to:

Legal reserve until the reserve equals 10% of share capital


Long term capital gains reserve (reserve special des plus-values a long terme)

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(3) Admissible taxes

In addition to those taxes described at DT7252 the 15% and 3.3% surcharges are admissible; the 1.5% surcharge is inadmissible.

Tax should be reduced by reimbursable credits for R&D, training, start ups etc.