Reform of the statutory corporate tax rate

Olivier Arnal (DGFIP), Ugo Di Nallo, Jean-Philippe Martin (Insee)

Documents de travail
No 2025-18
Paru le :Paru le02/09/2025
Olivier Arnal (DGFIP), Ugo Di Nallo, Jean-Philippe Martin (Insee)
Documents de travail No 2025-18- September 2025

Between 2016 and 2022, the standard corporate tax rate was reduced from 33 1/3% to 25%, bringing France closer to the OECD average. To assess the effects of this reform, this study relies on the gross implicit tax rate. This rate measures corporate income tax (excluding tax credits) relative to net operating surplus, a common indicator of corporate economic profit. It thus provides an assessment of the actual tax burden, independent of financing methods or tax base calculation rules.The gross implicit tax rate declined from 20.7% in 2016 to 17.5% in 2022 for market-sector companies, excluding the financial and agricultural sectors, and excluding the effects of the CICE and CET reforms. The gap between the standard rate and the implicit rate — both in level and in trend — is explained by the existence of reduced rates (which remained stable over the period) and by variations in the taxable base. The recovery in financial and exceptional results during this period notably made the taxable base more dynamic than the net operating surplus. These average trends mask contrasting developments depending on the type of company. The gross implicit tax rate for SMEs, which was higher in 2016 (23.1%), fell by only 1.7 percentage points over the period. It remains significantly higher than that of large enterprises, which was initially lower (19.3%) and declined by 5.0 points. In contrast, the implicit tax rate for SMEs has converged toward that of very small enterprises (VSEs), whose rate slightly increased over the same period (+0.4 percentage points).