Relocation
Some research may move abroad.
Tax reform · Plan de Rupture
6.06 — Remove the research tax credit for large companies
The Plan proposes removing the research tax credit for large companies. An operational draft must define large companies, tax groups, multi-year projects and prior commitments.
What the Plan proposes
Plan source: 5,5 milliards d’euros par an annoncés dans le Plan. The title and stated effect are preserved from the public edition; this page adds an initial legal and operational architecture for expert review.
The Plan proposes removing the research tax credit for large companies. An operational draft must define large companies, tax groups, multi-year projects and prior commitments.
Status: structured civic prototype requiring expert review before filing or implementation.
Current system
The CIR rate is 30% on research expenditure up to €100 million and 5% above it. That expenditure threshold is not itself a company-size definition.
Implementation path
- Define large companyUse a national or EU definition and address groups.
- Choose transitionDecide treatment of previously committed expenditure.
- Amend the Tax CodeRewrite eligibility, calculation and controls.
- Measure displaced researchTrack scientific jobs, outsourcing and lab location.
Key risks
Groups
Legal fragmentation must not bypass the rule.
Multi-year contracts
Investment decisions relied on existing law.
Gross estimate
Expected revenue must reflect behaviour.
Indicators to publish
| Indicator | Before | After | Purpose |
|---|---|---|---|
| Scope and population | Baseline | Annual value | Prevent perimeter changes |
| Budget effect | Estimate | Cash collected or spent | Separate promise from execution |
| Transition cost | Disclosed | Multi-year tracking | Calculate net effect |
| Appeals and errors | Initial rate | Corrected rate | Protect rights |
Updated doctrine: full CIR abolition
The former distinction between large companies and smaller firms is superseded. Current doctrine abolishes the French R&D tax credit for all company sizes, subject only to a transition for legally acquired claims. Measures 6.06 and 6.07 form one financial package and must never create two separate savings entries.
The Senate estimates the 2026 CIR tax expenditure at €8.041 billion. That figure is a gross benchmark, not an automatically bankable net saving because R&D behaviour, taxable profits and investment decisions can change. Read the complete corporate-tax redesign.