Rejection of the PLF 2025: stages, amendments and further parliamentary discussions

November 14, 2024

Background and main amendments to the Finance Bill 2025

The Finance Bill for 2025, which has been under discussion in the French National Assembly for the past few weekswas rejected by MPs in a vote held on Tuesday.

The initial draft, in the version approved by the Finance Committee in October, will now be discussed by the Senate.

In accordance with the Constitution, this first reading must be completed within 40 days, before November 21.

As a reminder :

The initial draft did not include any changes to the research tax credit (so the amendments concerning its modification were not adopted).
Amendments concerning the renewal of the innovation tax credit were also rejected. As it stands, the bill therefore stipulates that it will not be renewed after December 31, 2024.
The research collaboration tax credit (CICo) has been brought into line with European regulations.

The draft is subject to change before final promulgation.

Chronology of the Finance Act

Please find below the timeline for discussion and approval of the Finance Act, as the government can decide at any time to use Article 49.3 and promulgate the law outside the "classic" legislative process.

You will also find a reminder of the amendments adopted during the discussions before the assembly.

Preparing and introducing the bill

The Finance Bill (PLF) is prepared by the Ministry of the Economy and Finance. After interministerial discussions, it is presented to the Council of Ministers, usually at the end of September, and then tabled before the National Assembly.

First reading in the French National Assembly

The National Assembly begins its examination, with debates in committees (notably the Finance Committee) and then in plenary session. Deputies can propose amendments, and discussions focus on the main budgetary orientations and government revenues. Once passed, the first reading of the Finance Act goes to the Senate.

First reading in the Senate

The Senate also examines the text in committee and then in plenary session. The senators can in turn amend the text. At the end of this first reading, there are often differences between the texts adopted by the Assembly and the Senate.

Parliamentary shuttle

The two chambers exchange their versions of the law through several readings (or shuttles). If they fail to reach agreement, a joint committee (made up of deputies and senators) is convened to try to work out a compromise text.

Final adoption

If no compromise is reached, the National Assembly has the final say and may adopt the text on final reading. In this case, it can impose its version of the law.

Possible referral to the Constitutional Council

Once the law has been passed, it may be referred to the Constitutional Council to verify its conformity with constitutional standards. This is often the case with finance bills, as they are complex and touch on sensitive issues.

Promulgation of the law

Once validated (or corrected), the law is promulgated by the President of the Republic and published in the Journal Officiel before January 1 of the following year. It then comes into force, providing a framework for the State budget for the year 2025.

In the Finance Committee, several sensitive points were discussed, and numerous amendments had profoundly modified the initial text.

Main amendments adopted

1. Innovation Tax Credit (CII) and Collection Tax Credit (CIC)

Extensions The CII has been extended until December 31, 2027 to support innovation. An impact assessment is planned for Corsica, where the rates remain specific (40 % for small companies, 35 % for medium-sized companies).
Collection tax credit Maintained until 2027 to support the textile-clothing-leather sector, with the aim of preserving jobs and competitiveness.

2. research tax credit (cr)

Eligibility The financial sector remains eligible for the CIR, despite proposals to exclude it and refocus the scheme on industry and agriculture.
Terms of use :
- Large companies will not be able to convert the CIR into a tax reduction.
- 10-year business continuity commitment to avoid CIR refunds in the event of relocation.
Eligible expenses :
- Property depreciation and young doctors : Continued eligibility, with improved coverage for young doctors.
- Time tracking : No new doctrinal clarifications for the moment.
- Technology watch : Excluded, but patent and standardization costs remain eligible.
New rates :
- Increased rate of 50 % for research projects not involving animals.
- Rate of 30 % for projects complying with the EU's green taxonomy.

3. Video Games Tax Credit (CIJV)

Extension to 2031 with one restriction: prototyping expenses will only be taken into account once provisional approval has been obtained.

4. green bonus

Extension to December 31, 2027 This applies to equipment for ships using clean energy, with additional support for small and medium-sized businesses.

5. IP Box diet

Proposals to limit access to the IP Box and to include the calculation of eligible profits in the participation scheme were rejected.

6. Young Innovative Company (JEI)

Social security exemptions The Assembly voted to abolish exemptions from employer contributions, and referred the matter to the Senate.
Creating an impact-based JEI : Under discussion to promote social and environmental innovation, benefiting from the same support as traditional start-ups.

Tax credit guidance and legislative process in the event of disagreement

These amendments reflect an effort to focus tax credits and support on priority sectors, with greater control over spending and more stringent monitoring requirements to ensure rigorous use of public resources.

Please note that it is not out of the question that senators will reintroduce into the text, presented at the Council of Ministers, the amendments that have so far been rejected during the vote on the revenue section of the LPF.

As indicated above, in the event of persistent disagreement between the Senate and the National Assembly, the draft may be submitted to the Joint Partisan Committee (CMP), whose task will be to draw up a joint text acceptable to both assemblies.

In the event of persistent disagreement, the National Assembly will have the final say, in accordance with the Constitution.

We will, of course, keep you informed of the project's progress until it is enacted.

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