IP box Active
French IP regime (Art. 238 CGI)
Preferential 10% rate on qualifying net income from patents, patentable inventions and copyrighted software, under an OECD-compliant modified-nexus design (in force since 2019, replacing the pre-2019 regime).
✓ 3 Jul 2026
Key parameters
| Reduced rate on qualifying IP income | 10% |
|---|---|
| Nexus conformity | Yes — modified nexus approach (OECD BEPS Action 5) |
| Qualifying IP | Patents, patentable inventions, and copyrighted software |
| Election | Optional, per asset or product/service family |
Eligibility
- HQ
- Any headquarters country
- Local presence
- Local tax presence required (branch is sufficient) A branch office (Zweigniederlassung/permanent establishment) of your existing company is enough — you do not need to form a new legal entity such as a GmbH or BV.
- R&D substance
- Required
- Company size
- No size restriction
- Revenue
- Bounded above €750M (Pillar Two 15% floor)
- Models
- Fabless design, IP licensing, IDM, EDA / tools
- Sectors
- All
- Goals
- IP domiciliation; Additional design site in Europe
Election per asset/family of assets; nexus ratio documentation required. For groups above €750M revenue, the benefit is bounded by the 15% GloBE floor.
Mechanism & application
Rule-based entitlement — Legal entitlement — self-assessment, no case-by-case funding decision.
Election in the corporate tax return with nexus-ratio documentation per IP asset or product family.
Timeline: Immediate (tax filing)
Legal basis & sources
- Legal basis
- Art. 238 CGI
- Verification
- CGI Art. 238 (10% rate on qualifying IP; modified nexus)
from 1 Jan 2019 until no expiry review 1 Jan 2027
Related
✓ Stacks with