France

CIT ~25.8% Pillar Two ✓

25% headline rate plus a 3.3% social surcharge for larger companies. The Crédit d'Impôt Recherche is Europe's largest R&D tax credit by fiscal cost (~€6.6bn/year), declaration-based with no pre-approval. Base was narrowed by LF2025; the credit itself survived LF2026 unchanged.

✓ 3 Jul 2026

Instruments (6)

R&D tax credit Active Rule-based entitlement

Crédit d'Impôt Recherche (CIR)

Europe's largest R&D tax credit by fiscal cost (~€6bn/year): 30% of eligible R&D expenses up to €100M, 5% above, declaration-based with no pre-approval. Refundable immediately for SMEs, JEI, and new companies; after 3 years for others. The base was narrowed by the 2025 Finance Act but the headline rate was left unchanged.

Rate: 30% on first €100M of eligible R&D expenses; 5% above
Refundable: Immediately for SMEs, JEI, new companies; after 3 years for others
Base narrowing (LF2025, from 15 Feb 2025): Operating-cost flat rate cut 43% → 40% of personnel; young-doctors doubling abolished; patent filing/defence fees and tech-watch expenses excluded
Estimated annual fiscal cost: ~€6 billion

✓ 3 Jul 2026

IP box Active Rule-based entitlement

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).

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

✓ 3 Jul 2026

Payroll exemption Active Rule-based entitlement

Jeune Entreprise Innovante (JEI)

Status for young R&D-intensive SMEs granting employer social-contribution exemptions for R&D staff (plus local-tax exemptions on approval). The R&D-expenditure threshold was raised to 20% of charges in 2025.

Main benefit: Employer social-contribution exemption for R&D personnel
R&D threshold: ≥20% of charges (raised from 15% in 2025)
Age limit: Company < 8 years old
Caps: Per-employee 4.5× SMIC; per-company 5× annual PASS

✓ 3 Jul 2026

R&D tax credit Active Rule-based entitlement

Crédit d'Impôt Innovation (CII)

A companion to the CIR for SMEs: a tax credit on innovation expenditure for the design/prototyping of new products (beyond pure R&D). Reserved for SMEs, on a capped expenditure base.

Rate: 20% of eligible innovation expenditure
Expenditure cap: €400,000 per year (→ max ~€80k credit)
Scope: Prototypes & pilot installations of new products (SMEs only)

✓ 3 Jul 2026

Grant program Active Discretionary (call-based)

France 2030 / Électronique 2030 (Bpifrance)

The national investment plan's electronics strand: >€5bn of state support for the electronics/semiconductor value chain through 2030, delivered as grants, co-investment and the i-Demo innovation programme, administered by Bpifrance.

Electronics envelope: >€5bn to 2030 (within the ~€54bn France 2030 plan)
Axes: Manufacturing capacity · frontier R&D · skills
Vehicles: Grants, co-investment, i-Demo innovation programme
Administrator: Bpifrance / SGPI

✓ 3 Jul 2026

Expat tax ruling Active Rule-based entitlement

Impatriate tax regime (Art. 155 B CGI)

Tax relief for employees recruited from abroad to work in France: the impatriation bonus is income-tax exempt, and part of foreign-source income and passive income is also exempt, for up to 8 years.

Impatriation bonus: Income-tax exempt (actual amount, or 30% flat option)
Extra exemptions: 50% of certain foreign-source investment/capital income
Duration: Up to 8 years (until end of 8th year after arrival)

✓ 3 Jul 2026

Ecosystems

Grenoble

Grenoble, Auvergne-Rhône-Alpes

LogicRISC-V / Open ISAPhotonicsMEMS / SensorsPower (SiC/GaN)

STMicroelectronics and Soitec anchor the valley; CEA-Leti provides pilot-line and RISC-V cooperation routes.

CEA-Leti — FD-SOI, photonics, and advanced memory pilot lines; strong RISC-V program.
Grenoble INP / UGA — Microelectronics engineering pipeline.

FDI screening & export control

⚠ Semiconductors in scope

Threshold: 25% voting rights generally; 10% on a temporary basis for sensitive listed companies; acquiring a business unit can also trigger review
Authority: Direction Générale du Trésor (Bercy) — Bureau CIEF
Timeline: ~30 working days initial phase, up to 45 further working days if escalated to in-depth review

Among the most active EU regimes (417 filings reported for 2025). Semiconductors are explicitly listed as a critical technology, and scope was recently expanded so both R&D activity and production of critical technologies trigger mandatory screening (previously R&D-only) — this is one of the few regimes where setting up new R&D activity, not just acquiring an existing company, can itself be in scope. Verify current guidance before committing to a specific structure.

Legal basis: Code monétaire et financier, Art. L151-3; IEF guidelines revised 30 July 2025 — source ↗ ✓ 3 Jul 2026

Labor law snapshot

Works council: Comité Social et Économique (CSE) mandatory at 11+ employees, with expanded competencies at 50+
Notice periods: Set primarily by the applicable convention collective (sector CBA) rather than statute — Syntec (engineering/tech services) is the common reference for design/R&D roles
Bargaining: Very influential — sector CBAs routinely set minimum salary grids, notice periods, and redundancy procedures (PSE) for larger layoffs

✓ 3 Jul 2026 · orientation only, verify with local counsel

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