In France, additional measures that extend or suspend certain time limits have been implemented in response to COVID-19, and it was announced that certain corporate tax measures that have already been announced and implemented in the context of the COVID-19 crisis would be subject to an additional condition.

Conditionality of corporate tax measures

On 27 March 2020, the French Ministry of Finance announced that the favorable tax measures on which we previously reported would be conditional upon the absence of dividend distributions during 2020 by the relevant taxpayer (failing which, the taxpayer may have to reimburse the cash advance with penalties). Further details on this condition are expected to be provided in the coming days.

Additional measures

Additional temporary measures have been implemented by the French Government on 25 March 2020, in particular regarding deadlines and statutes of limitations applicable to tax matters during the state of public health emergency. Subject to certain conditions:

• certain deadlines applicable to taxpayers that intend to bring an action before competent tax courts have been extended
• the statutes of limitation for tax audits and for the recovery of taxes by the French tax authorities have been suspended
• certain deadlines applicable to taxpayers and the French tax authorities in the context of tax audits and tax rulings have been suspended

It is, however, expressly provided that time limits for the filing of tax returns are not impacted by these measures; tax returns must be filed in accordance with the time limits given by the normal rules. Notably, this means that companies with a financial year end on 31 December 2019 must file their corporate income tax returns in May 2020.