2024 could be a profitable year for the French state coffers. Since January 1, French multinationals have in theory no longer had any reason to outsource the payment of their taxes to a tax haven. Last November, France transposed a European directive into its 2024 finance bill (PLF), itself the result of an agreement concluded in 2021 within the inclusive framework of the OECD comprising 140 countries. This provides for the creation of a minimum global tax of 15% on the profits of multinationals, which ensures that whatever its location, it does not pay less taxes than elsewhere.
A measure that has gone rather unnoticed in the national public debate, yet the result of important negotiations at the global level. The aim of this agreement, even more powerful when transposed into the law of the countries having voted for it, is to put an end to the transfer of profits in “tax havens” – territories with very low taxes. In addition to the 27, Australia, Canada, Japan, Korea, Liechtenstein, Malaysia, New Zealand, the United Kingdom and Switzerland are already working on implementing this tax in their tax system. This new tax must apply to companies with a turnover of more than 750 million euros, or fewer than 10,000 firms worldwide.
Up to 220 billion in global profits
This reform should help to drastically limit tax competition, since in the event that a territory continues to apply a rate lower than 15%, France would, thanks to the law, be able to take the difference from the multinational’s profits. housed in this state. “Companies will benefit from fair conditions of tax competition on an international scale thanks to the implementation of the minimum corporate tax”, welcomed the Minister of the Economy Bruno Lemaire, upon its adoption .
According to initial estimates, this measure could allow France to receive between 1.5 and 4 billion euros in revenue per year from 2026, and up to 220 billion dollars per year globally. A significant profit, but smaller compared to the 600 billion annual losses linked to tax avoidance estimated by the fiscal affairs department of the International Monetary Fund (IMF). Some economists also consider this minimum ceiling too lax. “A rate of 15% is far too low. Within the Icrict, we support a rate of 25%”, recommended last November Nobel Prize winner Joseph Stiglitz, 2001 Economics Prize and co-president of the Independent Commission for reform of international corporate taxation (Icrict).
In fact, this new law leads to the creation of an additional tax included in the PLF. It is added to corporate tax, and does not exempt from the Gafa tax (3% on turnover), introduced in France in 2019. The latter is still not adopted at the level international, and constitutes the first pillar of the OECD agreement, which remains under negotiation. If “pillar 1” of the reform is adopted, the OECD expects additional tax revenue of between 13 and 36 billion euros. This Gafa tax will only be applied in France when an international multilateral convention has been adopted by the members of the agreement.