The New Limitation on the Deduction of Financial Expenses

With retroactive effect to fiscal years ending on or after 31 December 2012, the Finance Law for 2013 has introduced, in addition to existing rules, a general limitation on the tax deduction of finance expenses incurred by companies for corporate income tax purposes, as codified under article 212 bis and 223 bis of the French Tax Code. This note describes the main features of the new provision and how it is expected to interact with existing interest deduction limitation provisions.