Question 26926 — corporate tax

Summary

Ms Émilie Cariou questions the Minister of Economy and Finance about the so-called “Cope niche” mechanism. French law grants a preferential rate to the taxation of capital gains derived from transfers of company securities in the case of a holding company (known as the “Cope niche” mechanism). In 2020, the budgetary cost of this niche was officially evaluated at 7.022 billion euros realized in 2018, in the documents annexed to the project of the 2020 finance law. Within this mechanism, tax law imposes a minimum share for financial costs and charges (QPFC) which remains subject to the normal rate of tax on profits (second paragraph of a quinquies of I of article 219 of the general tax code). This logic of minimum floor taxation was at the start of the five-year term at 4% (12% of the 33 1/3 of common law). With the drop in the facial rate on all companies, mathematically this minimum tax is falling and has - for the moment - not yet been readjusted. The MP asks him for the following information: per year, from 2015 to 2019, what was the average budgetary cost per company or group of companies concerned generated by the exemption based on this article a quinquies of I of article 219 of the general tax code? ; per year, from 2015 to 2019, what was by company or group of companies the median budgetary cost generated by the exemption based on this article a quinquies of I of article 219 of the general tax code? ; per year, from 2015 to 2019, what were the median and average budgetary costs generated by the exemption based on this article a quinquies of I of article 219 of the general tax code for the 10 companies or groups of companies that most benefited from this exemption? ; per year, from 2015 to 2019, what were the shares in the benefit of this exemption between, respectively, VSE SMEs and companies with turnover of 250 million or more? What was the geographical distribution, region by region? ; what extra-budgetary evaluations are made a posteriori of the companies or groups of companies having benefited from this exemption? What about the development of their activity? economy and jobs created or eliminated in France and Europe after the operation allowing them to benefit from this exemption? What effect in particular on employee profit-sharing? Finally, she asks what economic and socio-economic assessment is made of the attractiveness or uselessness of this tax measure, placed in the more general context of all measures favorable to investment in companies, and being considered in Europe the other compulsory deductions outside the central state, to which the taxation of capital gains of companies in France is often extremely quickly compared.

Machine translation from French. The official text remains authoritative.

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• Émilie Cariou · auteur

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