Tax reform · Plan de Rupture

6.07 — Reform the research tax credit for SMEs and mid-caps

The measure aims to focus support on SMEs and mid-caps and must state whether this means a higher rate, faster refunds, a cap or simpler controls.

6.07 — Reform the research tax credit for SMEs and mid-caps
6.07 — Reform the research tax credit for SMEs and mid-caps

What the Plan proposes

Plan source: 2 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 measure aims to focus support on SMEs and mid-caps and must state whether this means a higher rate, faster refunds, a cap or simpler controls.

Status: structured civic prototype requiring expert review before filing or implementation.

Current system

The CIR uses common eligible-expense rules and rate bands. SME, mid-cap and group definitions require precision.

Implementation path

  1. Define beneficiariesSet staff, turnover, independence and consolidation rules.
  2. Choose the leverRate, refund, advance, cap or simplified control.
  3. Prevent artificial SMEsConsolidate groups and dependency links.
  4. Evaluate additionalityMeasure research genuinely created by the support.

Key risks

Deadweight

Planned research may receive aid without new activity.

Control

Simplification must not admit non-research costs.

Cash flow

Refund timing matters for young companies.

Thresholds

Cliff effects may discourage growth.

Indicators to publish

IndicatorBeforeAfterPurpose
Scope and populationBaselineAnnual valuePrevent perimeter changes
Budget effectEstimateCash collected or spentSeparate promise from execution
Transition costDisclosedMulti-year trackingCalculate net effect
Appeals and errorsInitial rateCorrected rateProtect rights

Updated doctrine: residual CIR reform becomes phase-out

Measure 6.07 is no longer interpreted as preserving a special CIR for SMEs and mid-caps. It becomes the legal transition layer of the full phase-out: treatment of existing claims, closure of linked rules and coordination with the new general 15–30% profit-tax schedule.

The policy objective is to replace an expertise-intensive tax expenditure with lower, simpler and more predictable general taxation rather than recreating another credit under a different name.

Official sources

  1. BOFiP — taux du crédit d’impôt recherche
  2. budget.gouv.fr — documents budgétaires 2026