Corporate tax loss carryforward and carryback in France 2026
The two French corporate-loss mechanisms: an unlimited carryforward capped each year (€1,000,000 + 50%) and an optional one-year carryback generating a tax credit. Rules, deadlines and pitfalls.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. A loss-making company can carry losses forward, with no time limit, but the annual offset is capped at €1,000,000 plus 50% of the profit above that threshold. It may also elect carryback against the single preceding year only, within €1,000,000 and that year's profit, generating a tax credit that can be offset or refunded.
2026 context: a cash-flow issue#
Loss carry rules are stable in 2026, but often poorly used. A company running two consecutive loss years can lose part of its carry rights if it does not manage its filings. The stake is direct: a well-used loss reduces corporate tax, and a carryback election not made in time is lost for good.
Carryforward: unlimited in time, capped per year#
Carryforward (Article 209-I of the tax code) is the default mechanism: a loss in one year can offset profits in later years, with no time limit. The annual offset is, however, capped at €1,000,000 plus 50% of the profit above €1,000,000.
| Profit of the year | Maximum loss offset |
|---|---|
| €800,000 | €800,000 (limited to profit) |
| €1,000,000 | €1,000,000 |
| €1,500,000 | €1,000,000 + 50% × €500,000 = €1,250,000 |
| €3,000,000 | €1,000,000 + 50% × €2,000,000 = €2,000,000 |
Example: an SME has a €2,000,000 carried-forward loss at the start of 2025, a year in which it makes a €1,500,000 profit. The offset cap is €1,000,000 + (50% × €500,000) = €1,250,000. It offsets €1,250,000; its taxable profit is €250,000, and the remaining loss (€750,000) stays carryforward, with no time limit, to later years.
Note: the carried-forward loss is lost on cessation of activity or a major change of activity, and a change of control can limit its use (Articles 209-I and 209-II of the tax code).
Carryback: a tax credit#
Carryback (Article 220 quinquies of the tax code) is an election to offset a year's loss against the profit of the single preceding year only, within a double limit:
- the loss carried back cannot exceed €1,000,000;
- it cannot exceed the prior year's profit.
This offset creates a claim on the Treasury equal to the excess corporate tax previously paid. The share of loss not carried back stays carryforward.
Example: an SME closes 2025 with a €1,500,000 loss and had made a €1,200,000 taxable profit in 2024. It elects carryback: the loss carried back is capped at €1,000,000 (below the 2024 profit). The credit is €1,000,000 × 25% = €250,000, within the tax actually paid for 2024. The remaining loss (€500,000) is carried forward.
The election deadline#
The carryback election must be made within the filing deadline of the loss-year return, using the dedicated form (2039-SD). After that deadline, the election is lost and the loss falls solely under carryforward: the administration accepts no late correction.
The carryback credit: nature and use#
The credit is not taxable income. It can be:
- offset against corporate tax due in the next five years;
- refunded at the end of that five-year period if not offset;
- monetised with a credit institution (assignment of the claim).
In practice, when the company returns to profit, offset is often faster than waiting for a refund.
When to prefer carryback over carryforward?#
The choice between the two mechanisms is first a cash-flow decision. Carryback makes sense when the prior year generated significant tax: the credit arises immediately and can be monetised to fund the low point of the cycle. Conversely, when the company expects a quick return to profit, carryforward is often enough, with no formality.
Three criteria guide the decision:
- The tax paid last year: with no prior tax, there is no credit, so no reason to elect.
- Visibility on the years ahead: a fast return to profit favours carryforward; lasting uncertainty argues for securing a credit.
- The cash-flow need: the credit, which can be monetised with a bank, provides liquidity where carryforward only affects future tax.
In accounting terms, the carryback credit is recorded as an asset and does not affect taxable income; it is then offset against the instalments and balance of corporate tax in the following years.
Carryforward vs carryback: comparison#
| Criterion | Carryforward | Carryback |
|---|---|---|
| Time scope | Future years (unlimited) | Single prior year |
| Cap | €1,000,000 + 50% above | €1,000,000 |
| Election | Automatic | Optional (to be made) |
| Deadline | No formality | Before filing the return |
| Credit generated | No | Yes |
| Risk of loss | Cessation, change of control | Missing the election deadline |
Steps to elect carryback#
- Close the loss-making year and establish the tax result.
- Calculate the loss to carry back (at most €1,000,000, within the prior year's profit).
- Check the tax paid in the prior year.
- Complete form 2039-SD within the filing deadline of the result return.
- Keep the evidence of the election in the tax file.
Special cases and pitfalls#
- Trading or operating loss. Both follow the same carry mechanisms; no distinction is made.
- Merger or absorption. The absorbed company can transfer its losses to the absorbing company, subject to continuity and statutory conditions or approval; advice is recommended.
- Tax-consolidated companies. A subsidiary in a tax group cannot elect carryback on its own; carryback is assessed at group level.
- Reduced corporate-tax rate. An SME taxed at the reduced 15% rate on the eligible profit share offsets its losses against that rate: the tax saving is smaller, but the mechanism is identical.
2026 watch-points#
- Forgetting the carryback election. A return filed without the election forfeits the right, with no possible correction.
- Mis-qualifying the loss. A loss outside the carry regime generates neither carry nor credit.
- Misreading the cap. A company with €2,500,000 of carried-forward losses and €800,000 of profit offsets only €800,000 (profit below the cap), brings its taxable result to zero, and keeps €1,700,000 of carried-forward loss. The common error is to think the loss is "lost" if not fully used: it stays carryforward with no time limit.
- Ignoring a change of control. An undeclared takeover can put carried-forward losses at risk.
Our view as chartered accountants#
At Hayot Expertise, we regularly support SMEs and startups through alternating profit-and-loss cycles: a loss year, then a return to profit. A director's first reflex facing a loss is to think it is lost — it is not. The second trap is forgetting carryback, which could have generated a refundable credit.
We recommend quarterly monitoring as soon as a year trends toward a loss: forecast the result, estimate the loss, assess the value of carryback (especially if a prior year generated a large tax bill), and decide before year-end.
Hayot Expertise advice. If your year is trending toward a loss, hold a decision meeting before year-end to choose between carryforward and carryback. Carryback is irrevocable once declared, and its omission is final. A company profitable in prior years can convert part of its loss into a corporate-tax credit — provided it elects in time.
Frequently asked questions
Can I elect carryback retroactively, after filing my return?+
No. The election must be made within the filing deadline of the loss-year return. Once the return is filed without it, the right is lost and the deadline is strict.
Does carryback give an immediate refund?+
Not immediately. The credit is offset against corporate tax for the next five years, then any unoffset balance is refundable at the end of that period. Monetising it with a bank can speed up the cash.
Can I combine carryforward and a carryback election?+
Yes. An old loss carried forward can be offset against a profitable year while a recent loss is carried back. The two mechanisms coexist.
What happens to my carried-forward losses if I sell the business?+
A change of control or of activity can cause the loss of carried-forward losses, unless continuity is recognised. It is a valuation point to anticipate before any sale.
Is the carryback credit capped by the prior year's tax?+
Yes. If the prior year generated limited corporate tax, the credit cannot exceed that tax actually paid; the remaining loss is then carried forward.
Does carryforward have a maximum duration?+
No. Carryforward is unlimited in time; only the annual offset is capped. The unoffset balance stays available for future years.
Key takeaways#
- Carryforward is unlimited in time, but capped at €1,000,000 plus 50% of profit above that threshold.
- Carryback applies to the single prior year only, within €1,000,000 and that year's profit; the election must be made within the filing deadline.
- The carryback credit can be offset over five years, refunded at the end, and monetised with a bank.
- A cessation or change of control can cause the loss of carried-forward losses.
- Decide before year-end: the carryback choice must be made in time.
This article is current as of 5 June 2026 and provided for information. Any carryback election should be decided with your chartered accountant before year-end.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting firm based in Paris 8, whose founder is also a statutory auditor, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- BOFiP — Report en avant des déficits à l’IS (BOI-IS-DEF-10)
- BOFiP — Report en arrière des déficits, modalités (BOI-IS-DEF-20-10)
- BOFiP — Créance née du report en arrière (BOI-IS-DEF-20-20)
- impots.gouv.fr — Paiement du crédit d’IS issu du report en arrière de déficit
- Légifrance — Code général des impôts, article 220 quinquies (report en arrière)
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
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