Important: The information presented below is current as of November 18, 2025.
The upcoming parliamentary debates are likely to change its content. This article deals exclusively with the «revenue» section of the 2026 Finance Bill (PLF), which is currently under debate. The «expenditure» section will be examined separately in the coming weeks. The amendments detailed below are still subject to change during parliamentary discussions.
Analysis of measures adopted at first reading: CIR, CII, CICo, C3IV, and JEI; key points to remember in anticipation of 2026.
The vote on the first part of the 2026 finance bill (PLF 2026), which was on the National Assembly's agenda for the evening of Monday, November 17, following a delay, did not ultimately take place.
As they had not finished examining the numerous amendments still to be discussed, the members of parliament were unable to vote on the text as a whole. However, the fact that no vote was taken did not prevent the adoption of several structural measures affecting taxation of research, innovation, and industrial investment.
2026 Finance Bill: first reading still underway and a tight schedule
The measures adopted during these first reading sessions are part of an intermediate phase in the process of adopting the finance bill. The bill must now be examined by the upper house; senators will be able to:
- Amend articles voted on in the National Assembly,
- Introduce new amendments or delete certain provisions.
At the end of this stage, the text will be sent back and forth between the two chambers (the National Assembly and the Senate). In the event of persistent disagreement, the lower chamber, and more specifically the deputies, will have the final say on the final draft.
Against this backdrop of parliamentary uncertainty, several strong signals are nevertheless emerging regarding innovation taxation, outlining the broad guidelines that could shape the tax framework for R&D and investment in 2026.
2026 Finance Bill: Strong signals for innovation taxation in 2026
CIR and young doctors: return of doubling and operating costs at 230 %
The specific provision applicable to young doctors under the research tax credit (CIR), deleted by the Finance Act for 2025, has been reinstated. Prior to its removal, personnel expenses relating to young doctors were doubled in the CIR base, i.e., they were taken into account at 200 %. Amendment No. 2239 reintroduces this mechanism for young doctors recruited on permanent contracts.
In its initial version, the text provided for an operating cost rate of 90 %. This point was adjusted by amendment No. 3396, which raises this rate to 230 %. As it stands:
- The doubling of personnel expenses related to young doctors is restored ;
- Operating costs are calculated using a rate of 230 %, instead of the 90 initially planned.
CIR: exclusion of intermediation platforms from the tax base
Amendment No. 2576 excludes from the CIR tax base expenses paid to digital platforms or intermediaries whose main activity is to connect companies with service providers or researchers, without direct participation in the research work.
So, commissions or subscriptions paid to these intermediation platforms would no longer be eligible.
However, expenses corresponding to services involving actual involvement in R&D work may still be included in the CIR, subject to compliance with other legal conditions.
CIR and patents: exclusion maintained and new penalties in the event of relocation
Patent-related expenses, removed from the CIR by the Finance Act for 2025, are not reinstated at this stage. In addition, two mechanisms reinforce the obligations to maintain activity in France:
- Amendment No. I-823: penalties for relocation
- Reimbursement of CIRs received during the previous three fiscal years; ;
- Exclusion from the scheme for three years.
- Amendment No. 2947: stricter requirements for retaining the CIR
- No relocation for 10 years after receiving the tax credit; ;
- Maintaining operations in France (no site closures, no mass layoffs threatening continuity); ;
- Full refund of the CIR in case of non-compliance.
Innovation and AI tax credit: creation of the tax credit for artificial intelligence (CII IA)
Amendment No. 2235 creates a new innovation tax credit for artificial intelligence (CII IA). This measure would allow certain AI-specific hardware expenses to be included in the CIR tax base, in particular:
- GPU computing engines; ;
- CPUs used directly for R&D work or the development of AI-based solutions.
This expansion aims to support the growing computing capacity needs of artificial intelligence projects.
CICo: extension of the public-private partnership tax credit
The research collaboration tax credit (CICo), which was due to end on December 31, 2025, would be extended for three years by amendment no. 1880. This extension aims to provide long-term encouragement for partnerships between businesses and public bodies.
C3IV: an extended green industry tax credit to support investment
Amendment No. 3598 provides for the extension tax credit for investments in green industry (C3IV). The eligibility period for investments would thus be extended, strengthening multi-year visibility for industrial projects.
JEI: Young Innovative Company status extended until 2028
Amendment No. 1881 provides for a three-year extension the status of young innovative company (JEI). The associated tax benefits would be extended until December 31, 2028.
Our tax team will remain on standby throughout the parliamentary process and will keep you informed of any developments that may affect your tax arrangements.
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