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.
Key parameters
| 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 |
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
- Models
- All
- Sectors
- All
- Goals
- Additional design site in Europe; Manufacturing / fab site; R&D cooperation without own site; Access to pilot lines & prototyping
Expenses must relate to R&D performed in France (or the EEA for some categories). Contract research must go to accredited (agréé) providers.
Mechanism & application
Rule-based entitlement — Legal entitlement — self-assessment, no case-by-case funding decision.
Declaration-based: file form 2069-A with the corporate tax return. No pre-approval; optional rescrit (advance ruling) for certainty. Documentation must support the R&D qualification in case of audit.
Timeline: Immediate (tax filing); refund claims processed within months
Legal basis & sources
- Legal basis
- Art. 244 quater B CGI; base narrowed by Loi de finances pour 2025 Art. 55
- Verification
- CGI Art. 244 quater B / Loi de finances 2025 Art. 55 (promulgated 14 Feb 2025)
Changelog
-
15 Feb 2025
LF2025 Art. 55: operating-cost flat rate cut from 43% to 40% of personnel costs; young-doctors doubling abolished; patent fees and tech-watch expenses excluded from the base (for expenses incurred from 15 Feb 2025).
Source: Loi de finances pour 2025, Art. 55
Related
✓ Stacks with
See also