G/SCM/N/401/EU/Add.10  
 
31 October 2023  
(23-7362) Page: 1/24 
Committee on Subsidies and Countervailing Measures  Original: French  
 
  
SUBSIDIES  
NEW AND FULL NOTIFICATION PURSUANT TO ARTICLE XVI:1 OF THE GATT 1994  
AND ARTICLE 25 OF THE AGREEMENT ON SUBSIDIES  
AND COUNTERVAILING MEASURES  
EUROPEAN UNION 
Addendum  
The following addendum to the notification of the European Union, dated and received on 
25 October  2023, relates to subsidy programmes of France . 
 
_______________  
 
  G/SCM/N/401/ EU/Add.10  
 
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  Table of contents  
1   SPECIFIC SCHEMES  ................................ ................................ ................................ ..... 3 
1.1. FRAMEWORK SCHEME NO. SA. 58979 FOR REGIONAL AID FOR THE PERIOD 2014 -2023 3 
2   REGIONAL SCHEMES  ................................ ................................ ................................ ... 3 
2.1   Metropolitan France  ................................ ................................ ................................ ..... 3 
2.1.1 Tax exemption and reduction for new enterprises in regional aid areas  .........................  3 
2.1.2 Tax exemption and reduction for enterprises located in rural revitalization areas (ZRRs)  . 5 
2.1.3 Tax scheme to support start -ups in "priority development areas" (ZDPs)  ......................  6 
2.1.4 Optional exemptions from the territorial economic contribution (CET) and from property 
tax on buildings in rural busine ss revitalization areas and in town centre revitalization areas  ........  7 
2.2   Corsica  ................................ ................................ ................................ .......................  8 
2.2.1    Tax credit for certain investments made and exploited in Corsica  ................................ .... 8 
2.3 Overseas local communities (Overseas Departments and Regions and Overseas Communities 
(DROM -COM) and New Caledonia)  ................................ ................................ ........................  9 
2.3.1 Tax aid for productive investments in French overseas departments and territories  ........  9 
2.3.2 Tax reduction for profits from operations in the New Generation Free Zones for Activities 
(ZFAN Gs) in overseas France  ................................ ................................ ............................... 13 
2.3.3 Transport support measure for the French Overseas Departments  .............................. 14 
2.3.4 Call for projects - Digital territorial continuity in overseas France  ................................ 15 
2.4 Urban areas in difficulty  ................................ ................................ ............................. 16 
2.4.1 Tax concessions for enterprises located in urban free zones - entrepreneurship territories 
(ZFU-TEs) ................................ ................................ ................................ ......................... 16 
3   RESEARCH AND DEVELOPMENT (R&D) SCHEMES  ................................ ......................  18 
3.1 Framework scheme No. SA. 58995 for aid for research, development and innovation.  .......18 
4   SECTORAL SCHEMES  ................................ ................................ ................................ .. 19 
4.1   AID FOR SMEs ................................ ................................ ................................ ............ 19 
4.1.1    SME Aid scheme No. 100189 (formerly aid scheme No. SA. 59106)  ............................... 19 
4.1.2    Ultra-High-Speed Broadband Plan for France/ National Digital Society Fund (FSN)  ........... 19 
4.1.3   Tonnage -based tax scheme  ................................ ................................ ....................... 20 
4.1.4    Exceptional deduction scheme to support industrial SM Es' investments in digital 
transformation and robotization  ................................ ................................ ........................... 21 
4.1.5    Exceptional deduction scheme for investments in diesel fuel storage and distribution 
facilities  ................................ ................................ ................................ ............................ 22 
4.1.6    Exceptional deduction scheme for investments in off -road machinery to replace machinery 
running on off -road diesel (GNR)  ................................ ................................ ......................... 23 
 
  G/SCM/N/401/ EU/Add.10  
 
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  1  SPECIFIC SCHEMES  
1.1.  FRAMEWORK SCHEME NO. SA. 58979 FOR REGIONAL AID FOR THE PERIOD 
2014 -2023  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
In accordance with European regulations, this framework scheme for regional aid serves as the 
domestic legal basis for public interventions that contribute to the development of struggling 
territories, in particular by supporting initial investments by large enterprises and SMEs and/ or job 
creation related to initial investment.  
3. Legal basis (reference, date)  
Scheme No. SA. 58979  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Grant, loan, repayable advance  
5. Beneficiaries of the aid and allocation mechanism (calculation met hod and conditions)  
Beneficiaries (who receives the subsidy, the producer, the exporter, other)  
SMEs and large enterprises. Aid for large enterprises is restricted to initial investments in new 
economic activities.  
Eligible base: tangible and intangible as sets. 
 
Maximum aid levels:  
30% for small enterprises;  
20% for medium -sized enterprises;  
10% for large enterprises.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
• Amount for 2021: EUR 223.5 million  
• Amount for 2022: EUR 202.5 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The aid scheme applies until 31 December 2023.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
Scheme designed to help close the economic development gap between regions.  
 
2  REGIONAL SCHEMES  
2.1  Metropolitan France  
2.1.1  Tax exemption and reduction for new enterprises in regional aid areas  
1. Period covered by the notification  
2021 and 2022   G/SCM/N/401/ EU/Add.10  
 
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  2. Policy objective and/or purpose of the subsidy (or aid scheme)  
In order to promote the creation of new enterprises in areas with geographical, economic or social 
disadvantages, this aid scheme provid es for an exemption from taxes on profits made by new 
enterprises established in regional aid areas as determined on the basis of a map approved by the 
European Commission.  
3. Legal basis (reference, date)  
Article 44 sexies  of the General Taxation Code (CGI), deriving from Article 14 A of Law No. 88 -1149 
of 23 December 1988, extended by Article 92 -I of Law No. 99 -1172 of 30 December 1999 and then 
by Article 92 of Law No. 2003 -1311 of 30 December 2003, as amended by Article 8 7 of Amending 
Finance Law for 2006 No. 2006 -1771 of 30 December 2006, by Article 45 of Amending Finance Law 
for 2007 No. 2007 -1824 of 25 December 2007, by Article 62 of Amending Finance Law for 2009 
No. 2009-1674 of 30 December 2009, by Articles 108 and 12 9 of Finance Law for 2011 
No. 2010-1657 of 29 December 2010, by Article 47 of Amending Finance Law for 2014 
No. 2014-1655 of 29 December 2014, by Article 78 of Amending Finance Law No. 2015 -1786 of 
29 December 2015, by Article 223 of Finance Law for 2021 N o. 2020 -1721 of 29 December 2020 
and by Article 68 of Finance Law for 2022 No. 2021 -1900 of 30 December 2021.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Total exemption from profits tax until the end of the twenty -third month following the month of set -
up, followed by a reduction for profits earned over the three subsequent 12 -month periods (75%, 
then 50%, then 25%).  
 
Eligibility for the exemption is subject to compliance with Commission Regulation (EU) 
No. 1407/2013 of 18 Dece mber 2013 on de minimis  aid. 
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other) - New 
enterprises in the legal and economic sense (excluding resu mption, merging, restructuring, and 
extension of pre -existing activities), at least 50% of the share capital of which is held directly or 
indirectly by natural persons, and that are set up in specified areas.  
 
- Allocation mechanism - By operation of law.  
 
- Conditions - Genuinely new enterprises set up in eligible areas and the headquarters and all 
activities and operating resources of which are established in the area concerned. However, in the 
case of enterprises exercising a non -sedentary activity, conditio ns of establishment are considered 
to have been met if turnover generated outside eligible areas does not exceed 15% of total turnover 
(above this threshold, profits are taxed, but on the basis of turnover generated outside such areas).  
6. Subsidy per unit or , in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 69 million  
Estimated total amount for 2022: EUR 87 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The scheme is applicable to enterprises set up by 31 December 2023 in areas eligible for regional  aid. 
8. Statistical data permitting an assessment of the trade effects of the subsidy  
Around 13,400 beneficiary enterprises in 2021.  
 G/SCM/N/401/ EU/Add.10  
 
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  2.1.2  Tax exemption and reduction for enterprises located in rural revitalization areas 
(ZRRs)  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective and/or purpose of the subsidy (or aid schem e) 
In order to promote the creation or takeover of enterprises in areas with geographical, economic or 
social disadvantages, this scheme provides for an exemption from taxes on profits made by 
enterprises created or taken over in rural revitalization areas  determined in accordance with the 
objective criteria used to define rurality (density, income level).  
3. Legal basis (reference, date)  
Article 44 quindecies  of the General Taxation Code (CGI) derived from Article 129 of Finance Law 
for 2011 No. 2010 -1657 of 29 December 2010, extended by Article 29 of Amending Finance Law for 
2013 No. 2013 -1279 of 29 December 2013, by Article 47 of Amending Finance Law for 2014 
No. 2014-1655 of 29 December 2014, by Article 45 of Amending Finance Law for 2015 
No. 2015-1786 of 2 9 December 2015, as amended by Article 15 of Finance Law for 2016 
No. 2015-1785 of 29 December 2015, by Articles 17 and 18 of Law No. 2017 -1775 of 
28 December  2017, by Article 23 of Finance Law for 2019 No. 2017 -1837 of 30 December 2017, by 
Articles 19 and  135 of Finance Law for 2019 No. 2018 -1317 of 28 December 2018, by Article 223 
of Finance Law for 2021 No. 2020 -1721 of 29 December 2020 and by Article 68 of Finance Law for 
2022 No. 2021 -1900 of 30 December 2021.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Tax concession. Exemption from profits tax until the end of the fifty -ninth month following the month 
of set -up or takeover, followed by a reduction for profits earned over the subsequent 
three  12-month  periods (75%, then 50%, then 25%).  
 
Eligibility for tax exemption and partial tax exemption is subject to compliance with Commission 
Regulation (EU) No. 1407/2013 of 18 December 2013 on de minimis  aid. 
5. Beneficiaries of the aid and allocation mechanism (calculation method and  conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other) - Enterprises 
with fewer than 11 employees, at least 50% of the share capital of which is held directly or indirectly 
by natural persons, and that are created or taken  over in rural revitalization areas.  
 
- Allocation mechanism - By operation of law.  
- Conditions ‒  Enterprises with fewer than 11 employees, not engaged in excluded activities 
(e.g. banking, finance, insurance, management or property leasing), created or taken  over 
(excluding restructuring and extension of pre -existing activities) in eligible areas, and the 
headquarters and all activities and operating resources of which are established in one of the rural 
revitalization areas referred to in Article 1465 A of t he CGI. However, in the case of enterprises 
exercising a non -sedentary activity, conditions of establishment are considered to have been met if 
turnover generated outside eligible areas does not exceed 25% of total turnover (above this 
threshold, profits a re taxed, but on the basis of turnover generated outside such areas).  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 236 million   
Estimated total amount for 2022: EUR 294 million  G/SCM/N/401/ EU/Add.10  
 
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  7. Duration of the subsidy and/or any other time limits attached to it  
The scheme applies to enterprises created or taken over by 31 December 2023.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
33,600 beneficiary enterprises in 2021.  
 
2.1.3  Tax scheme to support start -ups in "priority development areas" (ZDPs)  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective  and/or purpose of the subsidy (or aid scheme)  
Support for start -ups in "priority development areas" (ZDPs), aimed at enhancing the attractiveness 
of rural and mountainous areas characterized by difficulties in integrating young people (15 -24 years 
of age) , high poverty levels and low population density.  
3. Legal basis (reference, date)  
Article 44 septdecies  of the General Taxation Code (CGI) deriving from Article 135 of Finance Law 
for 2019 No. 2018 -1317 of 28 December 2018, as amended by Article 223 of Finance Law for 2021 
No. 2020 -1721 of 29 December 2020 and by Article 68 of Finance Law for 2022 No. 2021 -1900 of 
30 December 2021.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Exemption from profits tax (income tax or corporation tax) for a period of five years. There is total 
exemption for the first two years, then a degressive exemption of 7 5%, 50% and 25% respectively 
for the following three years.  
In addition, from the year following their creation, such start -ups are also eligible for local tax 
exemptions, namely, from company land contribution (Articles 1463 B and 1466 B bis of the CGI), 
company value -added contribution (1 of II of Article 1586 ter of the CGI) and property tax on 
buildings (Article 1383 J of the CGI) for a period of 10 years, half of which is compensated by the 
State, the other half upon a decision by the local authorities . Thus, the taxable net bases may qualify 
for a total exemption for the first seven years, followed by a degressive reduction over the next 
three years, of 75%, 50% and 25% respectively.  
This tax scheme is expressly subject, under V of Article 44 septdecies  of the CGI, to compliance with 
Articles 13 and 14 of Commission Regulation (EU) No. 651/2014 of 17 June 2014 when the 
establishment is located in an area eligible for regional aid, and compliance with Article 17 of this 
Regulation when it is located outside such an area.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other) - This tax 
scheme to support start -ups in priority development areas (ZDPs) is restricted to small and 
medium -sized enterprises (SMEs) within the meaning of Annex I of Commission Regulation (EU) 
No. 651/2014 of 17 June 2014 declaring certain categories of aid com patible with the internal market 
in application of Articles 107 and 108 of the Treaty.  
 
- Allocation mechanism - By operation of law.  
 
- Conditions - SMEs engaged in an industrial, commercial or artisanal activity and created between 
1 January 2019 and 31 Dece mber 2022, located in a priority development area.  G/SCM/N/401/ EU/Add.10  
 
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  6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 1 million   
Estimated total amount for 2022: EUR 1 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The scheme applies to enterprises created by 31 December 2023.  
 
2.1.4  Optional exemptions from the territorial eco nomic contribution (CET) and from 
property tax on buildings in rural business revitalization areas and in town centre 
revitalization areas  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
Firstly, to support commercial activities located in rural business revitalization areas and, secondly, 
crafts and commercial activities located in town centre revitalization areas.  
3. Legal basis (reference, date)  
Articles 1464 F and 1464 G of the Ge neral Taxation Code; Articles 1382 H and 1382 I of the 
General Taxation Code.  
Articles 110 and 111 of Finance Law for 2020 No. 2019 -1479 of 28 December 2019.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Exemptions from the territorial econ omic contribution (CET) and from property tax on buildings.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
- Beneficiaries - 
 
Rural business revitalization areas: Under  II of Article 1464 G, the establishment must belong to 
an enterprise satisfying the following conditions: employ fewer than 11 employees; have an annual 
turnover excluding tax of less than EUR 2 million or a balance sheet total of less than EUR 2 million.  
 
Town centre revitalization areas: Under I of Article 1464 F, the establishment must be operated 
by an enterprise belonging to the category of micro, small and medium -sized enterprises (SMEs) 
within the meaning of Annex I of Commission Regulation (EU) No.  651/2014 of 17 June 2014 
declaring certain categories of aid compatible with the internal market in application of Articles 
107 and 108 of the Treaty.  
 
- Allocation mechanism - Upon option by the enterprise.  
 
- Conditions - The exemptions are subject to a decision by the municipality or public 
establishment for inter -municipality cooperation (EPCI) with its own tax revenues.  
 
Eligibility for exemption is subject to compliance with Commission Regulation (EU) No. 1407/2013 
of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning 
of the European Union to de minimis  aid. 
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  G/SCM/N/401/ EU/Add.10  
 
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  Total amount for 2021: unavailable  
Estimated amount for 2022: unavailable  
7. Duration of the subsidy and/or any other time limits attached to it  
Taxes established for the years 2020  to 2023.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
Unavailable  
 
2.2  Corsica  
2.2.1   Tax credit for certain investments made and exploited in Corsica  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To promote investment in Corsica in order to address the difficulties arising from the island's insular 
and rural nature.   
3. Legal basis (reference, date)  
Article 244 quater  E, 199 ter D and 220 D of the General Taxatio n Code (CGI), deriving from 
Article  48 of Law No. 2002 -92 of 22 January 2002 on Corsica. Article 244 quater  E was last amended 
by Article 39 of Amending Finance Law for 2011 No. 2011 -71978 of 28 December 2011, by Article  32 
of Amending Finance Law for 2012  No. 2012 -1510 of 29 December 2012, by Article 20 of Amending 
Finance Law for 2014 No. 2014 -891 of 8 August 2014, by Article 78 of Amending Finance Law for 
2014 No. 2014 -1655 of 29 December 2014, by Article 145 of Law No. 2015 -990 of 6 August 2015 
on growt h, activity and equal economic opportunities , by Article 78 of Amending Finance Law for 
2015 No. 2015 -1786 of 29 December 2015, by Articles 73 and 74 of Law No. 2016 -1917 of 
29 December 2016, by Article 17 of Amending Finance Law for 2017 No. 2017-1775 of 
28 December  2017, by Articles 22, 37, 135 and 152 of Finance Law for 2019 No. 2018 -1317 of 
28 December 2018, by Article 2 of Amending Finance Law for 2022 No. 2022 -1499 of 
1 December  2022 and by Articles 43, 44 and 45 of Finance Law for 2023 N o. 2022 -1726 of 
30 December 2022.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Tax credit equivalent to 20% of pre -tax investment costs or 30% depending on the size of the 
enterprise.  
5. Beneficiaries of the aid and allocation mechanism (calc ulation method and conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other) - Small 
and medium -sized industrial, commercial, crafts, liberal -professional and agricultural enterprises 
exploiting investments in Corsica.  
 
The ta x credit is subject to compliance with Article 14 of Commission Regulation (EU) No. 651/2014 
of 17 June 2014 declaring certain categories of aid compatible with the internal market in application 
of Articles 107 and 108 of the Treaty.  
 
- Allocation mechanism  - Upon option by the enterprise.  
 
- Conditions - Investments eligible for tax credit are those used in Corsica, other than 
replacement investments, and at least 25% of which is financed without State aid. Investments G/SCM/N/401/ EU/Add.10  
 
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  made in certain sectors of activity are excluded. Eligible investments must be used in Corsica for 
at least five years.  
 
For certain categories of enterprise (new enterprises, failing businesses, young innovative 
enterprises, SMEs covered by European law, etc.), receivables (amounts due) for tax credits 
calculated in respect of investments m ade as of 1 January 2012 are immediately repayable.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
Total amount of tax credit for 2021: EUR 109 million  
Estimated amount of tax credit for 2022: EUR 102 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The aid scheme applies to investments made up to 31 December 2027.  
8. Statistical dat a permitting an assessment of the trade effects of the subsidy  
Around 5,289 beneficiary enterprises in 2021.  
 
2.3 Overseas local communities (Overseas Departments and Regions and Overseas 
Communities (DROM -COM) and New Caledonia)  
2.3.1  Tax aid for productive investm ents in French overseas departments and territories  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To promote economic development in French overseas departments and territories.  
3. Legal basis (reference, date)  
- Article 199 undecies  B of the CGI; Article 217 undecies  of the CGI; Article 217 duodecies  of the 
CGI; Article 244 quater  W of the CGI, Article 244 quater  Y of the CGI.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Article 199 undecies  B of the CGI provides for a reduction in income tax for the benefit of individual 
investors domiciled in France or in the Overseas Departments and Regions who make productive 
investments (operating equipment) as part of a company subject to income tax. In the event of a 
lease payment reduction, an entity (carrier establishment) will raise the capital invested by 
taxpayers (non -partners), with a view to acquiring property and leasing it to the operating enterprise 
receiving the investment, by means of a lease -purchase contract. In return for their contribution, 
investing taxpayers benefit from a tax reduction. The lease charged to the operating enterprise is 
reduced by a minimum fraction of the overall tax advantage obta ined by the partners of the carrier 
establishment. At the end of the lease period, the operating enterprise becomes the owner of the 
property.  
Article 217 undecies  of the CGI (for investments made in the Overseas Departments and Regions) 
and Article 217 duodecies  of the CGI (for investments made in the Overseas Communities) provide 
for a tax deduction for enterprises subject to corporation tax that make productive investments in 
the overseas local communities. The tax deduction also applies to renovation an d rehabilitation work 
on hotels, tourist residences and classed holiday villages. The scheme enables such enterprises to 
deduct from their taxable income the amount of productive investments that they make directly. G/SCM/N/401/ EU/Add.10  
 
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  The use of a leasing arrangement is poss ible under the same conditions as those mentioned above 
for the scheme provided for in Article 199 undecies  B of the CGI.  
Article 244 quater  W of the CGI allows operating enterprises to benefit from a tax credit (income tax 
or corporation tax) for producti ve investments they make in the Overseas Departments and Regions. 
The operating enterprise may also acquire the property through a leasing contract, but the tax aid 
will always be paid directly to the operating enterprise.  
The new article 244 quater  Y, ado pted in the finance law for 2021, allows companies subject to 
corporation tax established in France or in a DROM to benefit from a tax reduction for new productive 
investments they make in Saint Pierre and Miquelon, New Caledonia, French Polynesia, Saint M artin, 
Saint Barthélemy, the Wallis and Futuna Islands and the French Southern and Antarctic Territories. 
This new scheme is intended to replace the scheme provided for in Article 217 duodecies  of the CGI 
applicable only in the overseas communities and in New Caledonia, with the aim of compensating 
for the reduction in the level of tax aid available to operators in these territories, resulting from the 
reduction in the rate of corporation tax in metropolitan France.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other)  
In all cases, the financial aid is awarded to the operating enterprise using the property that is the 
subject of the investment, that  is, an enterprise engaged in agricultural, industrial, commercial or 
crafts activities falling under Article 34 of the CGI. Pursuant to this Article, the profits made by 
natural persons exercising a commercial, industrial or crafts profession are consider ed as industrial 
and commercial profits, for the determination of income tax.  
Enterprises that may benefit from the provisions of Article 199 undecies  B of the CGI include 
individual enterprises or partnerships (with the exception of joint ventures) of whi ch the shares must 
be held directly by the taxpayer or through a single -person enterprise with limited liability. The tax 
reduction also applies to productive investments made by an enterprise subject to corporation tax 
of which the shares are wholly owned  by natural persons, where the investments are leased.  
Enterprises that may benefit from the provisions of Article 217 undecies  of the CGI include 
enterprises liable to corporation tax by operation of law or upon option, which make or create 
productive inv estments, or lease such investments. Where the legal person making the investment 
is the owner of the investment, but makes it available to an enterprise (leasing arrangement), the 
partners of the enterprise may nevertheless apply a deduction, under the co nditions cited above.  
Enterprises that may benefit from the provisions of Article 244 quater  W of the CGI include 
enterprises subject to corporation or income tax. Tax credit is also granted to enterprises that use, 
in a French Overseas Department, investm ents made available to them through a lease -purchase 
contract or leasing contract. Enterprises that may benefit from the provisions of Article  244 quater  W 
of the CGI include enterprises subject to corporation or income tax. Enterprises that may benefit 
from the provisions of Article 244 quater  W of the CGI are enterprises subject to corporation tax 
that make productive investments in the overseas communities and in New Caledonia.  
 
- Allocation mechanism  
Where the investment is carried out directly by the operating enterprise, the allocation of aid 
involves:  
- an income tax reduction for natural persons who are partners in a company subject to income 
tax through a cash contribution from the partners (Article 199 undecies  B of the CGI);  
- a deduction from the income taxable for corporation tax when they make inves tments in the 
Overseas Departments and Regions (Article 217 undecies  of the CGI);  G/SCM/N/401/ EU/Add.10  
 
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  - a reduction in corporation tax for companies subject to corporation tax established in France 
or in an Overseas Department or Region making an investment in the Overseas Com munities or in 
New Caledonia as part of a leasing arrangement (Article 244 quater  Y of the CGI);  
- a tax credit only for enterprises located in the Overseas Department or Region (Article 244 
quater  W).  
- When the investment is made through a leasing arrangeme nt, the aid takes the form of a 
lease payment reduction granted to the operator (Articles 199 undecies  B and 217 undecies  of the 
CGI).  
As regards property leasing arrangements, the financial aid in the form of a lease payment reduction 
is calculated on the  basis of a minimum fraction of the overall tax concession obtained by the 
investors or partners of the carrier establishment leasing the property to the operating enterprise 
through a lease -purchase contract.  
In the Overseas Departments and Regions, the S tate encourages farmers to use the tax credit for 
productive investments. Thus, since 1 January 2015, companies operating in the Overseas 
Departments and Regions have been excluded from the benefit of tax exemption (Article 199 
undecies  B, Article 217 undecies) where their turnover exceeded EUR 20 million in the last financial 
year. Concerning the tax reduction scheme provided for in Article 199 undecies  B of the CGI, the 
turnover threshold has been gradually lowered. It has thus been reduced to EUR 15 mill ion and 
EUR 10 million for investments made as of the financial years beginning on or after 1 January 2019 
and 1 January 2020 respectively. Enterprises with a turnover exceeding the above -mentioned 
thresholds therefore have no choice but to use the tax cre dit. Enterprises in Overseas Departments 
and Regions with a turnover below the above -mentioned thresholds can choose between the various 
tax exemption schemes and tax credit.  
Tax credits, like tax reductions and deductions from taxable income, may be subject to prior 
authorization from the Ministry responsible for the budget.  
Depending on the nature and/or amount of the investment made, two types of investment require 
the prior approval of the tax authorities:  
-  investments in "sensitive" sectors, reg ardless of the amount of the investment project 
(Articles  199 undecies  B and 217 undecies  of the CGI), which include investments in the 
following: the transport, recreational boating, agriculture, sea fishing and aquaculture sectors, 
the coal and iron and steel industries, the shipbuilding or synthetic fibres sectors and the 
automotive industry; and investment in relation to the restoration and rehabilitation of graded 
hotels, tourist accommodation and holiday villages;  
-  investments exceeding a certain am ount (EUR 250,000 or EUR 1 million, depending on the 
situation).  
- Conditions  
Aid is granted exclusively for new productive investments (permanent or durable operating resources 
capable of functioning autonomously) made for the benefit of an enterprise en gaged in industrial, 
commercial, crafts or agricultural activities.  
Aid is not allocated for investments made in certain sectors of activity specified in Article 199 
undecies  B of the CGI (trade; cafés, tobacconists and bars/public houses and catering; bus iness 
advisory services and consultancy; education, health and social welfare; banking, finance and 
insurance; all real estate activities; car repair, rental/leasing services without operators; business 
services; leisure, sporting and cultural activities; postal services; and investments in installations 
generating electricity from solar radiation). Commission Regulation (EU) No. 651/2014 of 
17 June 2014 also provides for specific conditions for the authorization of this aid.  
In order to benefit from the ai d, investments subject to prior approval for tax purposes must meet 
the following additional requirements:  G/SCM/N/401/ EU/Add.10  
 
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  - offer an economic interest for the department in which it is made. Such economic interest is 
assessed in relation to the economic profitability of the planned operation and its likely impact on 
the local economy;  
- seek to create or safeguard jobs in the department as one of its main goals;  
- fit in with the policy on land -use management, the environment and sustainable development;  
- ensure the protection of investors and third parties.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Article 199 undecies  B: 
Total amount for 2021: EUR 462 million   
Estimated total amount for 2022: EUR 589 million  
 
Article 217 undecies : 
Total amount for 2021: EUR 34 million   
Estimated total amount for 2022: EUR 29 million  
 
Article 244 quater  W: 
Total amo unt for 2021: EUR 158 million   
Estimated total amount for 2022: EUR 175 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The schemes provided for in Articles 199 undecies  B, 217 undecies  and 244 quater  W of the CGI are 
applicable until 31 December 2025.  
For Saint Martin, the new scheme provided for in Article 244 quater  Y of the CGI is applicable to 
investments made from 7 May 2022 until 31 December 2025.  
8. Statistical data permitting an assessment of th e trade effects of the subsidy  
Amount of tax aid for 2020: EUR 814 million  
 
Amount of tax aid for 2021: EUR 697 million  
 
Estimated expenditure for 2022: EUR 827 million  
 
In principle, the tax aid scheme could distort competition in the sectors that it indirectly targets in 
cases where, in a single market, certain enterprises can invest with funds that have benefited from 
the scheme (those that produce in the Overseas Departments and Regions), while others cannot 
(those that produce in metropolitan Franc e or elsewhere in Europe and export to the Overseas 
Departments and Regions).  
However, as part of the assessment of the scheme, an analysis was conducted in 10 sectors - the 
main sectors in which these two categories of enterprise compete - in order to eva luate whether 
such adverse effects are present by examining, sector by sector, trends in the respective market 
shares of overseas and metropolitan enterprises in the Overseas Departments and Regions.  
According to this analysis, the trends in the respective  market shares over the period covered were 
not significant or were negative for overseas enterprises. The market shares of overseas enterprises 
declined in 8 of the 10 sectors studied between 2015 and 2017. In 2 sectors, meanwhile, they 
experienced a mode rate increase over the period. Moreover, the main macroeconomic indicators 
point in the same direction by suggesting that the market share of non -overseas enterprises rose 
slightly over the period. The balance of trade in the Overseas Departments and Regio ns is still 
structurally in deficit (the trade deficit widened by almost 20% between 2010 and 2018).  
 G/SCM/N/401/ EU/Add.10  
 
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  2.3.2   Tax reduction for profits from operations in the New Generation Free Zones for 
Activities (ZFANGs) in overseas France  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To promote economic development and employment in the French Overseas Departments.  
3. Legal basis (reference, date)  
Article 44 quaterdecies  of the CGI, created by Article 4 of Law No . 2009 -594 of 27 May 2009 on 
policy on economic development in overseas France and amended notably by Articles 124 and 125 
of Law No. 2017 -256 of 28 February 2017 on planning for real equality in overseas France and other 
social and economic provisions and  Article 19 of Finance Law for 2019 No. 2018 -1317 of 
28 December 2018.  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Tax reduction for profits from operations in overseas France.  
5. Beneficiaries of the aid and allocation mechanisms (calculati on method and conditions)  
Beneficiaries (who receives the subsidy, the producer, the exporter, other) - SMEs subject 
to income tax or corporation tax that have operations in the free zones for activities in the French 
Overseas Departments (Guadeloupe, Guya na, Martinique, Mayotte or Reunion).  
 
Allocation mechanism - Optionally, application of the deduction by mentioning it on the income 
tax returns (extra -tax deduction on one of the tables of the tax return).  
- Conditions  
 
The profits of enterprises from operations located in the departments of Guadeloupe, Martiniqu e, 
Reunion, French Guiana and Mayotte are eligible for a reduction on their profits if they meet all of 
the following requirements:  
 
- They have fewer than 250 employees and their turnover is less than EUR 50 million,  
- The main activity of the operation f alls within one of the sectors eligible for the tax reduction 
for productive investment provided for in Article 199 undecies  B of the CGI (certain activities 
that were previously eligible are now excluded, for example business consultancy),  
- They are subj ect to an actual tax regime or one of the flat -rate regimes defined in 
Articles  50-0, 64 bis and 102 ter of the CGI (the so -called "micro enterprise" regime for 
industrial and commercial, agricultural and non -commercial matters).  
 
The scheme was made permanent on 1 January 2019. In addition, in order to benefit from the tax 
concession, the enterprise is no l onger obliged to incur expenses on vocational training or to make 
a payment to the Experimental Youth Development Fund.  
 
If all the requirements are met, the enterprise may apply a 50% reduction to the amount of its 
taxable profits for each financial year,  the amount of this reduction being limited to EUR 150,000.  
 
However, for profits from operations located in French Guiana and Mayotte, the reduction rate is set 
at 80% and the limit of this reduction is set at EUR 300,000. These same rates and limits are also 
applicable to profits from operations located in Guadeloupe, Martinique and Reunion and that carry 
out their main activity in a limited number of sectors (e.g. R&D, tourism, environment, etc.), as well 
as profits from operations located in these same three departments when these enterprises benefit 
from the inward processing procedure defined in Article 256 of Regulation (EU) No. 952/2013 of the 
European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code, 
provided that a t least one third of the operation's turnover, in respect of the financial year during G/SCM/N/401/ EU/Add.10  
 
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  which the reduction is applied, results from transactions involving goods that have benefited from 
this procedure.  
6. Subsidy per unit or, in cases where this is not possib le, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
- Total amount for 2021: EUR 84 million  
- Estimated amount for 2022: EUR 86 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The "new generation" ZFA scheme is applicable to financial years beginning on or after 
1 January  2019. The measure is no longer subject to a time limit.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
Around 6,800 enterprises concerned.  
 
2.3.3  Transport support measure for the French Overseas Departments  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
The objective of the measure is to foster regional economic development by providing support that 
seeks to offset:  
 
➢ the additional costs of transporting goods produced in the French Overseas Departments and 
Saint Martin within the national boundaries, and the additional costs of transporting primary 
products from their place of production to their place of processing;  
➢ the costs of transporting hazardous waste that cannot be treated or disposed of in the territories 
where it is produced (French Overseas Departments and Saint Mar tin). 
 
This measure was extended on 1 January 2018 to include trade between the French 
outermost regions and the waste sector under the Law on Real Equality in Overseas 
France.   
 
The aid scheme aims to offset the incremental costs arising from the structur al disadvantages related 
to the extremely remote location of the French Overseas Departments and French outermost 
regions. These incremental costs correspond to extra transport costs, in particular those generated 
by the lack of suitable local waste treatm ent plants and the need to send waste to mainland Europe 
or another French Overseas Department or French outermost region for treatment.  
3. Legal basis (reference, date)  
Law No. 2009 -594 of 27 May 2009 on the economic development of overseas France, and Artic le 24 
in particular.  
 
Decree No.  2010-1687 of 29 December 2010 on freight aid for enterprises in the French Overseas 
Departments of Saint Pierre and Miquelon, Mayotte, Saint Barthélemy, Saint Martin and the Wallis 
and Futuna Islands.  
 
Decree No. 2017 -1476  of 16 October 2017 on freight aid granted to enterprises in the 
communities governed by Article 73 of the Constitution, of Saint Pierre and Miquelon, 
Saint Barthélemy, Saint Martin and the Wallis and Futuna Islands.  G/SCM/N/401/ EU/Add.10  
 
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  4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Direct subsidy.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
Beneficiaries : Enterprises in all production sectors except the following: the automotive, synthetic 
fibres, iron and steel, and coal industries and the fisheries sector, as well as the agricultural products 
listed in Annex I to the Treaty on the Functioning of the European Union.  
 
Eligible expenses :  
 
- In geographical terms: the cost of transport between a French Overseas Department or a French 
outermost region and the European continent and inter -island transport in the Guadeloupe 
archipelago (importation).  
- Categories of expenditure: pre -tax cost of maritime or air transport, including insurance, 
handling and pre -clearance  temporary storage charges, of the following:  
o raw materials (primary or intermediate products) and equipment imported for 
introduction into an enterprise's production cycle;  
o locally produced finished products delivered to the European continent.  
 Aid for  waste transportation does not take into account the cost of long -term storage on 
non-approved platforms.  
- Basis of calculation: the cost of transport, irrespective of the European port or airport of origin 
or destination, is the cost of equivalent transpor t between the French Overseas Department or 
French outermost region concerned and continental France.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the av erage subsidy per unit in the 
previous  year)  
2020: EUR 5.8 million  
2021: EUR 4.1 million  
2022: EUR 3.6 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The scheme is in effect until 31 December 2023.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
Unavailable.  
 
2.3.4  Call for projects - Digital territorial continuity in overseas France  
1. Period covered by the notification  
2020 and 2021  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To support the purchase of capacity on extraterritorial electronic communication systems for Internet 
providers in overseas France in order to increase the scale and reduce the cost of their international 
connectivity.  
3. Legal basis (reference, date)  
Aid scheme  No. SA. 58994  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  G/SCM/N/401/ EU/Add.10  
 
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  Subsidy.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
Beneficiaries - Electronic communications operators as defined in Article L33 -1 of th e Postal and 
Electronic Communications Code that offer fixed or mobile Internet services to end customers in 
Guadeloupe, Martinique, Guyana, Réunion, Mayotte, Saint Martin, Saint Barthélemy and Saint Pierre 
and Miquelon.  
 
- Conditions - For eligible purchase s, the aid provided is based on a rate fixed according to the 
year of purchase. The table below indicates the rates used for this call for projects in 2017 and 2018, 
and the rates planned for the subsequent years, if the scheme is extended:  
 
Year of purcha se 2017 2018 2019 2020 2021 
Aid rate  50% 40% 30% 20% 10% 
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
2021: EUR 0.4 million  
2022: EUR 9.6 million  
7. Duration of the subsidy and/or any other time limits attached to it  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
2.4 Urban areas in difficulty  
2.4.1  Tax concessions for enterprises located in urban free zones - entrepreneurship 
territories (ZFU -TEs) 
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To revitalize economic activity and promote soc ial and professional integration in urban free zones 
- entrepreneurship territories (new designation of urban free zones since 30 December 2014).  
3. Legal basis (reference, date)  
Article 44 octies  A of the CGI, deriving from the aforementioned Law No. 2006 -396 
("third -generation" ZFU -TEs) replaces the measures provided for by Article 44 octies , which was 
repealed by Article 35 of Finance Law for 2022 No. 2021 -1900 of 30 December 2021.  
The exemption codified under Article 44 octies  A of the CGI, as amended by Article 157 of Finance 
Law for 2012 No. 2011 -1977 of 28 December 2011, by Article 42 of Ordinance No. 2013 -676 of 
25 July 2013, by Article 29 of Amending Finance Law for 2013 No. 2013 -1279 of 29 December 2013, 
by Article 48 of Amending Finance Law for 2014  No. 2014 -1655 of 29 December 2014, by Article  145 
of Law No. 2015 -990 of 6 August 2015 on growth, activity and equal economic opportunities, by 
Article 17 of Amending Finance Law for 2017 No. 2017 -1775 of 28 December 2017, by Articles 19 
and 135 of Financ e Law for 2019 No. 2018 -1317 of 28 December 2018, and by Article 68 of Finance 
Law for 2022 No. 2021 -1900 of 30 December 2021, is applicable to activities created between 
1 January 2006 and 31 December 2020 in all ZFU -TEs. These measures are also applicabl e, within 
the limits of the de minimis  regulations, to activities already engaged in before 1 January 2006 in 
the new ZFU -TEs established by the Law on equal opportunities. Activities created in 
"first generation" and "second generation" ZFU -TEs between 1 January and 2 April 2006 may be 
placed under the regime provided for in Article 44 octies  of the CGI or in that provided for in 
Article  44 octies  A of the Code.  G/SCM/N/401/ EU/Add.10  
 
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  4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Article 44 octies  A of the CGI  provides for an exemption from profits tax for five years, then a 
reduction of 60%, 40% and 20% for the first five, the sixth an d seventh, and the eighth and 
ninth 12-month periods following the exemption period, whether the enterprise employs five or 
more employees (Note: for activities created as of 1 January 2015, the reduction period has been 
lowered to 36 months).  
 
Exempt prof its may not exceed EUR 50,000 per taxpayer, per 12 -month period, increased by 
EUR 5,000 for each new employee hired as from 1 January 2015 who is domiciled in an urban policy 
priority neighbourhood or a ZFU -TE and is employed full time for a period of at l east six months.  
 
Eligibility for exemption is subject to compliance with Commission Regulation (EU) No. 1407/2013 
of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of 
the European Union to de minimis  aid.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
- Beneficiaries (who receives the subsidy, the producer, the exporter, other) - 
Enterprises engaged in industrial, commercial, crafts or non -commercial activities, for new or 
existing activities established in ZFU -TEs. 
- Allocation mechanism - By operation of law.  
 
- Conditions - Enterprises must carry out an actual activity in a ZFU -TE and must be physically 
established there, with operating resources for the activity engaged i n. In the case of non -sedentary 
activity established in a ZFU -TE but carried out entirely or partially outside of that zone, the activity 
is assumed to be carried out within a ZFU -TE when at least one sedentary full -time employee carries 
out his/her work w ithin the premises located in a ZFU -TE set aside for the activity, or when the 
enterprise realizes at least 25% of its turnover through clients located in the ZFU -TE. 
 
As for the 41 "second -generation" ZFU -TEs, new conditions have been established by Law 
No. 2003-1312 of 30 December 2003 regarding payroll numbers, turnover or balance sheet total, 
holding of capital when the enterprise has been set up as a company, and the enterprise's sector of 
activity. The conditions regarding payroll numbers and the hold ing of capital were relaxed by Law 
No. 2005 -32 of 18 January 2005 on planning for social cohesion.   
These conditions also apply to the new "third -generation" ZFU -TEs created by Law No.  2006-396 of 
31 March 2006.  
 
An additional condition has been establishe d for enterprises with at least one employee that have 
set up activities in a ZFU -TE between 1 January 2012 and 31 December 2014: Article 44 octies  A of 
the CGI provides that exemption from profits tax is subject to eligibility for the exemption from socia l 
charges laid down in Article 12 of Law No. 96 -987 of 14 November 1996 concerning implementation 
of the Urban Regeneration Pact.  
 
Note: New conditions relating to employees, in particular a local hiring clause, are envisaged for 
activities created in ZFU -TEs as of 1 January 2015. For activities created in ZFU -TEs as of 
1 January  2016, eligibility for exemption is subject to the exist ence, at 1 January of the year of 
establishment, of the city contract provided for in Article 6 of Law No. 2014 -173 of 21 February 2014 
on town planning and urban cohesion.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the a nnual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
Total amount for 2021 = EUR 139 million  
Estimated total amount for 2022 = EUR 132 million  
7. Duration of the subsidy and/or any other time limi ts attached to it  
Five years of total exemption, then a degressive reduction of 60%, 40% and 20% over nine years 
(reduced to three years for activities created as of 1 January 2015).  G/SCM/N/401/ EU/Add.10  
 
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  8. Statistical data permitting an assessment of the trade effects of the subsidy  
Around 16,000 beneficiary enterprises in 2021.  
 
3  RESEARCH AND DEVELOPMENT (R&D) SCHEMES  
3.1 Framework scheme No. SA. 58995 for aid for research, development and innovation.  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose  of the subsidy (or aid scheme)  
The aid scheme incorporates under one umbrella the research, development and innovation schemes 
notified for the period 2013 -2014 (technology research institutes and institutes for energy transition, 
the fund for enterprise competitiveness, the OSEO innovation aid scheme for research, development 
and innovation, aid for innovation in the shipbuilding industry, shared innovation platforms, young 
innovative enterprises).  
 
The aim of the scheme is to finance research and develop ment projects, upstream market research 
facilities and the dissemination of innovation in favour of SMEs or ecosystems.  
3. Legal basis (reference, date)  
Aid scheme No. SA. 58995  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
Subsidy (grant), repayable advance, loan, guarantee, exemption from social charges.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
SMEs and large enterprises. Rates of support range from 15% to 100% of the project's eligible 
amount, depending on the research phase financed through the project and the size of the 
enterprise. The smaller the enterprise and the further the activity is away from the market, the 
higher the possible rate of support.  
6. Subsidy per unit or, in cases whe re this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Amount for 2021: EUR 835 million  
Amount for 2022: EUR 1,000 million  
7. Duration of the subsid y and/or any other time limits attached to it  
1 January 2015 to 31 December 2023.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
An evaluation plan for framework scheme No. SA. 58995 for aid for research, development and 
innovation (R&D&I) was submitted to the European Commission.  
The evaluation, carried out in accordance with the European Commission's recommendations, aimed 
to measure the impact of the scheme both on its beneficiaries and on the economy in general.  
 G/SCM/N/401/ EU/Add.10  
 
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  4  SECTORAL SCHEMES  
4.1  AID FOR SMEs  
4.1.1   SME Aid scheme No. 100189 (formerly aid scheme No. SA. 59106)  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy  
The objective of the aid is to facilitate the development of SMEs ' economic activities, in particular by 
supporting their investment projects.  
3. Legal basis  
- Amended Decree No. 2014 -758 of 2 July 2014 on areas eligible for regional aid and SME investment 
support areas for the period 2014 -2020, in compliance with European Commission Decision 
No. SA. 38182 (2014/N) of 7 May 2014 adopting the French map of regional aid areas;  
- For local authority interventions: the General Code on Local Authorities (CGCT), particularly the 
provisions on economic interventions by local author ities. 
4. Form of the subsidy  
Subsidy (grant), repayable advance, loan, guarantee, tax exemption.  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  
Only SMEs within the meaning of Annex I of Regulation (EU) No. 651/2014 are  eligible for the aid.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 59.7 mi llion 
Total amount for 2022: EUR 12.7 million  
7. Duration of the subsidy and/or any other time limits attached to it  
The aid scheme applies until 31 December 2023.  
4.1.2   Ultra -High -Speed Broadband Plan for France/ National Digital Society Fund (FSN)  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective and/or purpose of the subsidy (or aid scheme)  
To ensure ultra -high-speed broadband coverage for the entire French territory by 2022.  
3. Legal basis (reference, date)  
Aid scheme No. SA. 37183  
4. Form of the subsidy (i.e. grant, loan, tax concession, etc.)  
5. Beneficiaries of the aid and allocation mechanism (calculation method and conditions)  G/SCM/N/401/ EU/Add.10  
 
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  6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy  (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 357 million  
Total amount for 2022: EUR 348.9 million  
7. Duration of the subsidy and/or any other time limits attached to it  
Scheme No. SA. 37183 providing  a framework for the Ultra -High-Speed Broadband Plan for France 
closed on 31 December 2022.  
8. Statistical data permitting an assessment of the trade effects of the subsidy  
4.1.3   Tonnage -based tax scheme  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective of the aid scheme  
To enable enterprises operating in the maritime transport sector to meet international competition 
and maintain high safety levels with regard to ships and navigation.  
3. Legal basis  
Article 209 -0 B of the CGI deriving from Article 19 of Amending Finance Law for 2002 No. 2002 -1576 
of 30 December 2002, as amended by Article 47 of Amending Finance Law for 2005 No. 2005 -1720 
of 30 December 2005, by Article 80 of Amending Finance  Law for 2006 No. 2006 -1771, by Article  75 
of Amending Finance Law No. 2014 -1655 of 29 December 2014 and by Article 34 of Finance Law 
for 2019 No. 2018 -1317 of 28 December 2018.  
4. Form of the aid  
Under this arrangement, the tax due as a result of operations directly linked to the use of certain 
ships (whether fully or jointly owned, or chartered on a bareboat or time basis) can be determined 
on a flat -rate basis. The flat rate is computed using a scale applied to each eligible vessel according 
to its net tonnage and increased, where appropriate, by certain amounts.  
5. Beneficiaries of the aid and allocation mechanism  
- Beneficiaries - Enterprises subject to corporation tax, at least 75% of whose turnover is 
generated by the operation of merchant vessels (including enterprises that are members of a group 
specified in Article 223 A or Article 223 A bis of the CGI, provided that all the enterprises in the 
group that are eligible for the tonnage -based tax choose this scheme).  
 
- Allocation mechanism - Upon opti on by the enterprise (or the group of enterprises eligible for 
the tonnage -based tax, as part of a tax group) made for an irrevocable period of ten years renewable 
at the end of that period.  
 
- Conditions - Option for the tonnage -based tax scheme is valid on ly if  
the percentage of net tonnage shipped by the enterprise under the flag of a member State of the 
European Union or the European Economic Area amounts to at least 25% at the date of 
commencement of the first period of implementation of the scheme and if, during the scheme's 
implementation period, the enterprise undertakes to maintain or increase the percentage of net 
tonnage shipped under the flag of a member State of the European Union or the European Economic 
Area at the date of commencement of the f irst period of implementation of the scheme.  
 G/SCM/N/401/ EU/Add.10  
 
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  Non-compliance with the requisite percentage of no less than 25% of the net tonnage carried by 
ships sailing under the flag of an EU or EEA member State at the date of commencement of the 
first period of implem entation of the tonnage -based tax scheme renders the option null and void.  
  
In the event of non -compliance with the undertaking to maintain or increase the percentage carried 
by EU - or EEA -flagged ships for a specific financial year, and subject to except ions, ships not sailing 
under the flag of an EU member State whose tonnage has reduced the percentage of net tonnage 
under the flag of an EU member State are not eligible for the tonnage -based tax scheme for that 
financial year. Exclusion is not definitive : these ships may benefit from the scheme for subsequent 
financial years, if the enterprise complies with its undertakings once again.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy  (indicating, if possible, the average subsidy per unit in the 
previous  year)  
Total amount for 2021: EUR 395 million  
Estimated total amount for 2022: EUR 3,810 million  
  
4.1.4   Exceptional deduction scheme to support industrial SMEs' investments in digital 
transformation and robotization  
1. Period covered by the notification  
2021 and 2022  
2. Policy objective of the aid scheme  
In order to encourage small and medium -sized enterprises (SMEs) to modernize their production 
facilities, this exceptional deduction scheme allows them to deduct from their taxable income 40% 
of the cost price of their investments in industrial robotization and digitalization.  
3. Legal basis  
Article 39 decies  B of the CGI created by Article 55 of Finance Law for 2019 No. 2018 -1317 of 
28 December 2018.  
4. Form of the aid  
Article 55 of Finance Law for 2019 No. 2018 -1317 of 28 December 2018 introduced an exceptional 
deduction from taxable income, codified in Article 39 decies  B of the General Taxation Code (CGI), 
to support the investme nts made by small and medium -sized enterprises (SMEs) in the field of 
robotics and digital transformation and assigned to an industrial activity.  
 
The deduction from taxable income, which applies to enterprises subject to corporation tax or income 
tax und er an actual tax regime, is equal to 40% of the original value of the property recorded in the 
fixed assets, excluding financial expenses.  
 
Entitlement to this increased rate is subject to compliance with Article 17 of the aforementioned 
Commission Regulation (EU) No. 651/2014 of 17 June 2014.  
5. Beneficiaries of the aid and allocation mechanism  
Beneficiaries - This scheme is reserved for small and medium -sized enterprises subject to 
corporation tax or income tax under an actual regime.  
 
- Allocation mechanism - By operation of law.  
 G/SCM/N/401/ EU/Add.10  
 
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  - Conditions -  
 
The tax deduction is spread on a straight -line basis over the normal useful life of the property. In 
the event that the property is sold or used for a non -industrial activity before the end of this pe riod, 
it is acquired by the enterprise only up to the amount already deducted from the income at the date 
of sale or change of use, which is calculated pro rata temporis . 
6. Subsidy per unit or, in cases where this is not possible, the total amount or the ann ual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
- Total amount for 2021: EUR 5 million  
- Estimated total amount for 2022: EUR 5 million  
7. Duration of the subsidy and/or any other time limits a ttached to it  
This exceptional deduction applies to property acquired new or manufactured between 
1 January  2019 and 31 December 2020, and to new goods leased under a leasing contract or a 
rental contract with a purchase option entered into between 1 Janua ry 2019 and 31 December 2020.  
 
Property acquired as from 1 January 2021 may also qualify for the exceptional deduction if they 
were ordered between 1 January 2019 and 31 December 2020 and an advance payment of at least 
10% of the total order amount was made, and if they have been acquired within 24 months of the 
order date.  
 
4.1.5   Exceptional deduction scheme for investments in diesel fuel storage and 
distribution facilities  
1. Period covered by the notification  
2021 and 2022  
 
2. Policy objective of the aid scheme  
Support the gradual withdrawal of the reduced rate for off -road diesel fuel (GNR).  
3. Legal basis  
Article 39 decies  G of the CGI, created by Article 60 of Finance Law for 2020 No. 2019 -1479 of 
28 December 2019.  
4. Form of the aid  
Article 60 of Finance Law  for 2020 No. 2019 -1479 of 28 December 2019 introduced an exceptional 
deduction from taxable income, codified in Article 39 decies  G of the General Taxation Code (CGI), 
for investments made by small and medium -sized enterprises (SMEs) that do not have faci lities for 
storing or distributing diesel fuel that is not coloured and traceable in storage facilities and in 
equipment for handling and distributing diesel fuel that is not coloured and traceable.  
The deduction is equal to 40% of the original value of t he property recorded in the fixed assets, 
excluding financial costs. The tax deduction is spread on a straight -line basis over the normal useful 
life of the property.  
5. Beneficiaries of the aid and allocation mechanism  
- Beneficiaries - This scheme is reserved  for small and medium -sized enterprises subject to 
corporation tax or income tax under an actual regime.  
 
- Allocation mechanism - By operation of law.  
 G/SCM/N/401/ EU/Add.10  
 
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  - Conditions –  
 
To qualify for the exceptional deduction, companies must:  
 
- Be subject to corporation tax or income tax under an actual regime;  
- Meet the definition of a small or medium -sized enterprise, as defined in Annex I of Commission 
Regulation (EU) No. 651/2014 of 17 June 2014 declaring certain categories of aid compatible with 
the intern al market in application of Articles 107 and 108 of the Treaty;  
- Be engaged in the retail of off -road diesel fuel and not have, as of 1 January 2020, facilities 
for storing and distributing diesel fuel that is not coloured and traceable.  
Entitlement to the deduction is subject to compliance with Article 17 of Regulation (EU) 
No. 651/2014.  
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the previous 
year)  
- Total amount for 2021: EUR 0  
- Estimated total amount for 2022: negligible amount  
7. Duration of the subsidy and/or any other time limits attached to it  
The exceptional deduction applies to property acquired new between 1 January 2020 and 
31 December 2022, and to new property leased under a leasing contract or a rental contract with a 
purchase option entered into between 1 January 2020 and 31 December 2022.  
 
4.1.6   Exceptional deduction scheme for investments in off -road machinery  to replace 
machinery running on off -road diesel (GNR)  
1. Period covered by the notification  
2021 and 2022   
2. Policy objective of the aid scheme  
Support the gradual withdrawal of the reduced rate for off -road diesel fuel (GNR).  
3. Legal basis  
Article 39 decies  F of the General Taxation Code, created by Article 60 of Finance Law for 2020 
No. 2019-1479 of 28 December 2019.  
4. Form of the aid  
Article 39 decies  F of the General Taxation Code (CGI) provides for two exceptional deductions to 
encourage the acquisition of off -road machinery using alternative fuels to off -road diesel fuel (GNR):  
- the deduction provided for in I of Article 39 decies  F of the CGI is applicable to building and 
public works enterprises, to enterprises producing solid mineral substances, to airport o perators, as 
well as to operators of ski lifts and ski areas, when purchasing certain off -road machinery;  
- the deduction provided for in II of Article 39 decies  F of the CGI is applicable only to building 
and public works enterprises when they purchase cert ain off -road machinery to replace equipment 
more than five years old that the enterprises used previously for the same purpose.  
5. Beneficiaries of the aid and allocation mechanism  G/SCM/N/401/ EU/Add.10  
 
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  - Beneficiaries - This scheme is reserved for enterprises subject to corporation tax or income tax 
under an actual regime.  
- Allocation mechanism - By operation of law.  
 
- Conditions -  
 
The deduction applies to off -road machinery, recorded as fixed assets, running on natural gas, 
electric power or hydrogen, as well as off -road machinery combining electric power and a petrol or 
E85 superethanol engine and those combining petrol with natural gas fuel or liquefied petroleum gas 
whose emissions are less than or equal to a value es tablished by decree, that fall into one of the 
following categories: equipment and tools used for industrial operations; handling equipment; 
engines installed in equipment.  
 
Eligibility for the exceptional deduction is subject to compliance with Commission  Regulation (EU) 
No. 1407/2013 of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the 
Functioning of the European Union to de minimis  aid. 
6. Subsidy per unit or, in cases where this is not possible, the total amount or the annual  amount 
budgeted for that subsidy (indicating, if possible, the average subsidy per unit in the 
previous  year)  
- Total amount for 2021: negligible  
- Estimated total amount for 2022: negligible  
7. Duration of the subsidy and/or any other time limits attached to it  
These exceptional deductions apply to property acquired new between 1 January 2020 and 
31 December 2022, and to new property leased under a leasing contract or a rental contract with a 
purchase option entered into between 1 January 2020 and 31 December 2022.  
 
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