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France: Tax-Efficient Sectors

Patent Holding Company

Resident patent holding companies pay a reduced corporate income tax rate (instead of the standard rate) on income received from entities in respect of patents licensed for exploitation. This concession does not apply if either:

  • The licensee is a resident French corporation which is associated with the licensor and which is subject to corporate income tax in France; or
  • The patent was not developed but was acquired and market value was not paid for the acquisition; or
  • Market value was paid for the acquisition but the acquisition took place less than 2 years ago.



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