Fiscal subject related
Main Objectives and Context
- France originally pushed for an EU-level tax
- As consensus failed—largely due to tax unanimity rules—France acted unilaterally.
- The DST will be repealed once a global agreement (Pillar 1 of the OECD reform) is implemented. While Pillar 2 (global 15% minimum tax) has been adopted via the 2024 Finance Act in France, Pillar 1 remains pending.
Scope of the Tax
- Applies to companies—regardless of domicile—whose global taxable digital revenues exceed €750 million, and at least €25 million generated in France.
- Thresholds are assessed at group level, including related entities.
- Two service categories are taxed:
- Digital platforms enabling user interaction, like online marketplaces.
- Targeted digital advertising services based on user data.
- Exemptions: traditional e-commerce (resale model) and digital content delivery.
Tax Rate and Collection
- The DST is 3% of annual gross (excl. VAT) revenue from taxable services in France.
- It is reported via the March CA3 VAT return and payable by April 25 of the following year.
- Payment rules:
- Simplified VAT regime filers: declare on CA12, no advance payments.
- Monthly CA3 filers: must pay two installments:
- 1st in March, alongside the final balance for the prior year.
- 2nd in September.
France’s DST is a transitional measure aimed at pressuring global agreement on digital taxation while ensuring immediate revenue from major tech firms profiting from the French digital market. The tax is narrowly targeted, administratively integrated with existing VAT procedures, and meant to be temporary, pending OECD reforms. However, until Pillar 1 is implemented, the DST remains a key national tool for addressing digital tax gaps and leveling the playing field for domestic businesses.
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Already subscriber? LoginNew document was uploaded: S4F backoffice patch
S4F backoffice patch is intended for users who have already installed S4F backoffice and are intended to update existing installations to latest version. To do so apply only patches that are marked with version number that is newer than your currently installed instance of backoffice. Please make sure to install all available patches sequentially (without skipping). This package contains instruction, release notes, changelog and software packages required for deployment of this software component. Read more