Nearly fifteen years ago, the Finance Act for 2012 introduced an apparently temporary tax — the exceptional contribution on high incomes (CEHR) — conceived “in a context of reducing public deficits and restoring our public finances,” and to “ask for an exceptional effort from the most affluent taxpayers” [1]. The public deficit at the time stood at €103 billion, or 5.3% of GDP, and was moreover declining compared to 2010 [2]. Parliamentary records reveal that the contribution as initially proposed was to apply through the 2013 tax year, justifying the use of the qualifier “exceptional” [3]. The Finance Committee of the day, though dominated by the right, had removed this time limit on the grounds that the government’s “reluctance to tax the wealthiest” was “unacceptable” — without, however, changing the name of this new contribution.

In 2024, the public deficit stands at €168.6 billion, or 5.8% of GDP — this time rising compared to the previous year [4] — and not only has the “exceptional” contribution not disappeared, but lawmakers, ever eager to plug a stubbornly persistent deficit, have given the CEHR a younger sibling in the form of the “differential contribution on high incomes,” further burdening the supposedly “most affluent” individual taxpayers who have not yet crossed the border.

Two lessons seem to emerge from this semantic sleight of hand: first, in tax law, the “exceptional” can easily become the “structural”; and second, lawmakers — and behind them, the Directorate for Tax Legislation — have a vast vocabulary at their disposal for giving their fiscal inventions names that are as reassuring as they are misleading.

The terminological proximity of the recent “exceptional contribution on the profits of large companies” to the aforementioned exceptional contribution on high incomes offers a rather unpromising outlook as to how “exceptional” this new levy will prove to be. This new charge — added to the roughly four hundred and eighty taxes, duties, contributions and levies already known to our country [5] — applies to the profits of corporate income taxpayers, at a rate of 20.6% of corporate tax (IS) for taxpayers with pre-tax turnover between one and three billion euros, and 41.2% of IS for those with pre-tax turnover exceeding three billion euros [6]. As a result, a company with a turnover above three billion euros will face an effective corporate income tax rate not seen since the Mitterrand era [7].

The analogy holds on the level of stated intentions as well, since the ambition is to “contribute to the restoration of our public accounts” by “targeting the largest companies” [8]. Parliamentary records further reveal that this new contribution is indeed designed to be temporary [9].

The current drafting of the Finance Bill for 2026 should prompt the more astute observer to ask: will this exceptional contribution on the profits of large companies be maintained? One may note that, unlike the exceptional contribution on high incomes — which was directly codified by the Finance Act for 2012 — the exceptional contribution on large companies’ profits remains inscribed solely in the Finance Act for 2025 [10], meaning that in the absence of its inclusion in the Finance Act for 2026, it would lapse. Credit for this absence of codification is owed to the Government [11] — a circumstance that would be entirely reassuring only if the Government still commanded a majority in the National Assembly.

The answer was initially… in the affirmative. On 14 October 2025, a Finance Bill for 2026 was tabled in the National Assembly, whose Article 4 renewed the exceptional contribution on large companies’ profits for one year [12]. The rates were originally to be halved — from 20.6% to 10.3% and from 41.2% to 20.6% respectively — as had already been anticipated at the time of the Finance Act for 2025’s adoption — but a government amendment voted on 27 October ultimately revised these rates to 5% and 35.3%, concentrating the burden on companies with turnover above €3 billion.

The explanatory memorandum to Article 4 states that this renewal is for one year only. Beyond the limited confidence we are entitled to place in such an assertion, it is worth recalling that an exceptional contribution on profits had already been introduced for the year 2017 under broadly similar circumstances — though at lower rates [13]. The temporary character was indeed honoured on that occasion, but the regular re-adoption of a similar contribution at recurring intervals would not make it any less “exceptional” — particularly since the underlying context driving it, namely the public deficit, is itself structural.

Fortunately, the Senate saw fit to hold the Government to its word. On 29 November last, through three amendments directed against Article 4 of the Finance Bill, the upper chamber voted to suppress the extension of the exceptional contribution on large companies’ profits. The senators responsible for this salutary censure noted that the extension “undermines the credibility of the government’s word in light of the commitments made before the Senate Finance Committee by the Minister for Public Accounts, who declared in June 2025 that ‘certain points can be stated plainly: the corporate tax surcharge will no longer exist in 2026′” [14]; that it “cannot be justified, given that French companies are already among the most heavily taxed in the world” [15]; and that it “constitutes a breach of the commitment made by the Government in the last Finance Act, which explicitly limited it to a single budgetary year” [16]. The press release concluded: “The Senate’s vote restores the credibility of the government’s word and improves the predictability and stability of the tax framework applying to entrepreneurs in France” [17].

It remains to be seen what compromise will be reached in the Joint Committee (Commission mixte paritaire), with the hope that the National Assembly will yield — for the perpetuation, or regular reintroduction, of this exceptional contribution on large companies’ profits, mirroring what happened with the high-income contribution, would obviously be regrettable. Indeed, while this contribution is expected to concern fewer than five hundred French companies [18], and many point to the fact that the implicit corporate tax rate is higher for SMEs than for large companies [19], it has very recently come to light that the one hundred and seventeen companies that are members of the Association française des entreprises privées (AFEP) — almost all of which have pre-tax turnover exceeding one billion euros — already account for 19% of all taxes and contributions paid by all companies in France, while representing only 13% of value added [20]. This amounts to a total of €85.1 billion; given that parliamentary projections for revenues from the exceptional contribution on large companies’ profits stand at eight billion euros for 2025, it is clear that this “exceptional contribution” is very far from being a mere drop in the ocean of the tax burden already borne by large companies.

The explanation for this regrettable divergence of perception — which leads to an ever-increasing burden being placed on France’s largest companies — is that attention tends to focus almost exclusively on the high-profile corporate income tax, whose welcome reduction since 2018 [21] is moreover more than offset, for companies with turnover above three billion euros, by the exceptional contribution on profits. What this overlooks is that the heaviest component of mandatory levies consists of social contributions, which are estimated to have amounted to €53.6 billion in 2024 for the one hundred and seventeen AFEP member companies — representing 62% of their total fiscal burden.

Beyond this cognitive bias, the overlapping media and political cycles will readily lead one to draw a causal link between this exceptional contribution on large companies’ profits and the controversy surrounding TotalEnergies’ so-called “superprofits” for 2023, widely covered in early 2024. The journalistic and popular indignation at the fact that a French company was functioning profitably almost certainly provided all the political cover needed — if any were needed — to propose an additional contribution on large companies’ profits. Rather less attention was paid to the effect that this public flogging — compounded by pressure from environmentalist groups — very likely had on the decision to pursue the “sidestep” to America that followed, with our national oil major opening a secondary listing in New York.

For far from enabling any realistic hope of long-term fiscal balance, the accumulation of these taxes, surtaxes, and additional and exceptional contributions produces in reality destructive indirect effects, as it erodes corporate investment. In this regard, it is worth recalling that while French companies have indeed benefited over the past decade from several significant incentives — notably the Research Tax Credit and the now-defunct Competitiveness and Employment Tax Credit — France nevertheless maintains one of the highest average effective tax rates in the OECD, and indeed the third highest in the European Union [22]; to which must be added, once again, social contributions. More broadly, it is always worth reiterating that France is the OECD country where the ratio of mandatory levies to GDP is the highest (43.8% in 2023) [23], across all taxes and contributions combined.

Unfortunately, much as the reports of the Court of Auditors are never read, it seems likely that the relentless accumulation of these publicly available data points will not factor into the judgment of lawmakers. Whether or not the exceptional contribution on large companies’ profits is retained, the trend toward increasing fiscal pressure will in all likelihood continue its course — toward the far reaches of a Laffer curve that, in the case of France, has long since merged with the vertical axis.

But after four hundred and eighty different levies, what new names can be found for the future fiscal inventions that will inevitably come? After such a prodigious lexical effort, where can inspiration still be found? This poses a formidable semantic challenge for the Directorate for Tax Legislation. Nevertheless, since tried-and-tested recipes are rarely abandoned, all that remains is to await — within fifteen years, though almost certainly much sooner — the arrival of the differential contribution on large companies’ profits.

[1] Assemblée nationale, Exposé des motifs du projet de loi de finances pour 2012, 28 sept. 2011

[2] INSEE, Les comptes des administrations publiques en 2011, mai 2012

[3] Débat de la Commission des finances sur le Projet de loi de finances pour 2012

[4] INSEE, Le compte des administrations publiques en 2024, mai 2025

[5] D’après un décompte de la Fondation pour la recherche sur les administrations et les politiques publiques, publié en juin 2021

[6] Art. 48 de la Loi n°2025-127 du 14 février 2025 de finances pour 2025

[7] Jusqu’en 1985, le taux d’impôt sur les sociétés était ainsi de 50%, cf. Caubet-Hilloutou J.N., Girard P., Redondo P., La baisse du taux de l’impôt sur les sociétés depuis 1986 : une analyse à partir de données individuelles d’entreprises. Économie & prévision, n°98, février 1991

[8] Assemblée nationale, Exposé des motifs du projet de loi de finances pour 2012, 10 octobre 2024

[9] Rapport général du Sénat sur le projet de loi de finances pour 2025, Tome II, Fascicule I, 21 novembre 2024

[10] Ainsi qu’à l’ordonnance n° 2013-837 du 19 septembre 2013 relative à l’adaptation du code des douanes, du code général des impôts, du livre des procédures fiscales et d’autres dispositions législatives fiscales et douanières applicables à Mayotte

[11] Rapport général du Sénat sur le projet de loi de finances pour 2025, Tome II, Fascicule I, 21 novembre 2024

[12] Article 4 du Projet de loi de finances pour 2026 n°1906, déposé le 14 octobre 2025

[13] Article 1 de la loi n°2017-1640 du 1er décembre 2017 de finances rectificative pour 2017

[14] Amendement présenté par M. Husson au nom de la Commission des finances, 24 novembre 2025

[15] Amendement présenté par MM. Capus, Malhuret et s., 26 novembre 2025

[16] Amendement présenté par Mme Lavarde, M. Darnaud et s., 24 novembre 2025

[17] Sénat, Communiqué de presse, Le Sénat supprime la surtaxe d’impôt sur les sociétés pour l’exercice 2026, 29 novembre 2025

[18] Rapport général du Sénat sur le projet de loi de finances pour 2025, Tome II, Fascicule I, 21 novembre 2024

[19] D’après une étude de l’INSEE de septembre 2025, intitulée « Le taux d’imposition implicite des profits entre 2016 et 2022 est plus élevé pour les PME que pour les grandes entreprises », qui a fait l’objet de nombreux commentaires médiatiques.

[20] AFEP, dixième édition de l’Enquête sur les contributions économiques et fiscales des entreprises membres, septembre 2025

[21] Article 84 de la loi n° 2017-1837 du 30 décembre 2017 de finances pour 2018

[22] Données OCDE

[23] Données OCDE