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3.2. Practical Aspects of Tax Residence

France applies a limited territorial system, whereby only profits made by enterprises (regardless of their nationality) operated in France are liable to corporate income tax in France.

This means that French companies are not subject to tax in France on business profits realized abroad (but are subject to tax on passive income from whatever source). Likewise, a foreign company is liable to French corporate income tax only on the profits realized by enterprises operating in France.

The expression "enterprise operated in France" refers to an enterprise carrying on a regular business in   France, whether through an autonomous establishment, through representatives with no independent professional status, or as part of operations forming a complete business cycle.