France 2026 Exceptional Corporate Tax Surcharge (CEBGE): What Large Groups and Mid-Caps Must Know

In our work with French tax-consolidated groups, the same questions have been coming up since the 2026 Finance Act was passed: does the CEBGE apply to our group perimeter, how do we model the average corporate tax base, and how do we secure the December advance payment without incurring penalties? This article provides precise, up-to-date answers — current as of 24 May 2026 — for finance directors managing their group's tax compliance.

Quick answer. The contribution exceptionnelle sur les bénéfices des grandes entreprises (CEBGE) — France's exceptional corporate tax surcharge on large businesses — is a temporary levy on top of corporate income tax (IS), extended for 2026 by the 2026 Finance Act (loi n° 2025-1680). It applies to groups whose consolidated worldwide revenue exceeds €1.5 billion. The rates are 20.6 % (bracket from €1.5 billion to €3 billion) and 41.2 % (above €3 billion), applied to the arithmetic average of IS paid in 2025 and 2026. An advance payment representing 98 % of the estimated amount must be made no later than 15 December 2026.

The CEBGE — contribution exceptionnelle sur les bénéfices des grandes entreprises — was originally introduced for fiscal year 2025 against the backdrop of a severely deteriorating public deficit. With the deficit estimated at around 4.6 % of GDP in 2025, the legislature chose to extend the mechanism to 2026 without major structural changes, though it did raise the entry threshold.

The 2026 Finance Act (loi n° 2025-1680) formalises this extension. The CEBGE is not a levy on revenue or on equity. It is a surcharge on corporate income tax itself, which produces a specific calculation mechanics.

The Budgetary Context Behind the Measure#

The original €1 billion consolidated revenue threshold had triggered intense parliamentary debate. The Senate proposed outright abolition of the surcharge. The joint committee (commission mixte paritaire) resolved the disagreement by raising the threshold to €1.5 billion, thereby removing a significant portion of the most exposed mid-caps (ETI). This compromise explains why the 2026 scope is narrower than that of 2025.

The CEBGE operates on a two-bracket structure based on the group's consolidated worldwide revenue:

The combined effective rate is an approximation based on the standard 25 % IS rate. It varies depending on each group's actual tax position.

How Is the Average IS Base Calculated?#

The CEBGE base is not solely the IS for the current year. It is the arithmetic average of the IS due for 2025 and the IS due for 2026.

In practice:

• Add the final 2025 IS and the projected 2026 IS together.
• Divide by two.
• Apply the CEBGE rate corresponding to the relevant revenue bracket.

This smoothing mechanism reduces the impact of one-off years, but it creates a practical difficulty: when the December 2026 advance payment falls due, the final 2026 IS is not yet known. Finance teams must therefore work from a robust estimate.

Example 1 — Group with €1.7 billion revenue#

A French industrial group has consolidated revenue of €1.7 billion. It falls within the lower bracket (€1.5 billion to €3 billion). Its 2025 IS was €38 million. Its projected 2026 IS is €42 million.

• Average IS: (38 + 42) / 2 = €40 million
• CEBGE: €40 million × 20.6 % = €8.24 million
• Advance payment due 15 December 2026: €8.24 million × 98 % = €8.08 million

This amount is in addition to the standard quarterly IS instalments. It must be provisioned on the balance sheet from the first interim accounts.

Example 2 — Group with €4 billion revenue#

A retail group has consolidated revenue of €4 billion. It falls within the upper bracket (above €3 billion). Its 2025 IS was €95 million. Its projected 2026 IS is estimated at €105 million.

• Average IS: (95 + 105) / 2 = €100 million
• CEBGE: €100 million × 41.2 % = €41.2 million
• Advance payment due 15 December 2026: €41.2 million × 98 % = €40.38 million

At this scale, the CEBGE represents a substantial additional tax burden. Our practical experience on comparable files: groups that did not factor this amount into their annual cash-flow plan find themselves under short-term financing pressure in November and December.

Meeting the 98 % threshold is critical: an underestimated advance payment triggers late-payment interest on the shortfall.

This is the most frequent question we have received since January 2026. The penalty mechanism mirrors that applying to standard IS instalment payments (CGI, article 1668).

If the advance paid in December is less than 98 % of the CEBGE finally due:

• Late-payment interest applies to the shortfall, at the statutory rate then in force;
• A surcharge may apply where the shortfall is material and deliberate.

The practical difficulty is real: the final 2026 IS is not settled in December. Groups must therefore build a reliable IS 2026 estimate from October onwards, drawing on interim accounts and projections.

Key Controls to Avoid the Penalty#

• Draw up a set of accounts to 30 September 2026 before computing the advance payment.
• Document the assumptions used for the projected 2026 IS.
• Build in a safety margin in the estimate rather than targeting the bare minimum.

Anonymised case from our files — On a recent engagement (French industrial group, consolidated revenue €2.1 billion), the initial internal estimate of the CEBGE came to €4.2 million. After reviewing the tax-consolidation perimeter and correcting the 2025 IS figure used, the relevant average IS was adjusted downwards and the final amount settled at €3.8 million. A discrepancy of this size — manageable once identified — illustrates the value of a second opinion before the December payment is made.

Yes. This is a point that international groups frequently underestimate. The CEBGE applies wherever the consolidated worldwide revenue of the group exceeds €1.5 billion, even if the French subsidiary on a standalone basis does not reach that level.

Concretely: a French subsidiary of a US group with global revenue of €5 billion is subject to the CEBGE, calculated on its French IS, at the rate applicable to the bracket above €3 billion.

This treatment aligns the tax position of French subsidiaries with that of French-headquartered groups of equivalent size. In practice it requires coordination between local tax management and the group parent, notably to obtain the consolidated revenue figure and the IS data needed for the calculation.

What Happens When the Threshold Is Crossed During the Year?#

The €1.5 billion threshold is assessed over the full fiscal year. Three practical scenarios recur in our files:

• Organic growth: a group that crosses the threshold in 2026 having been below it in 2025 enters the CEBGE's scope from that fiscal year. The average IS base is still calculated on 2025 plus 2026, which can produce a lower effective burden in the first year of exposure.
• Acquisition: an external growth transaction that pushes consolidated revenue above the threshold triggers liability. The consolidation perimeter used must be documented precisely (date of first consolidation, accounting method).
• Disposal or demerger: conversely, a disposal that brings consolidated revenue below €1.5 billion may take the group out of scope. The effective date of the transaction — closing date versus accounting date — is critical.

In all cases, the threshold is not assessed month by month but over the full fiscal year. A contradictory review with your adviser before year-end is advisable if your group is trading close to the threshold.

In a French tax-consolidated group (intégration fiscale), it is the parent company at the head of the group that is liable for the consolidated IS. The CEBGE is calculated on this consolidated IS, not on the individual IS of each subsidiary.

Specific points of attention for tax-consolidated groups:

• The revenue figure used to determine the applicable bracket is the revenue of the consolidated group, a concept distinct from the tax-consolidation perimeter. Verifying which perimeter is used is essential.
• Losses brought into the tax consolidation reduce the consolidated IS, and therefore the CEBGE base. This is a lever worth analysing.
• Where a company enters or leaves the tax-consolidated group during 2025 or 2026, the reference average IS may be affected. A review of perimeter entries and exits is necessary.

In our experience, it is this point — the interaction between the tax-consolidation perimeter and the CEBGE perimeter — on which tax directors are spending the most analytical time in 2026.

For further guidance on group tax structuring, see our dedicated page on holding company tax advice in Paris.

No. The CEBGE is not deductible in computing the taxable profit for IS purposes. It is a non-deductible tax charge, which must be added back in the tax reconciliation schedule (form 2058-A for companies subject to IS).

This treatment has a direct consequence: the CEBGE does not reduce the IS base in subsequent years. It adds to total tax cost without any future tax amortisation effect.

Raising the threshold from €1 billion to €1.5 billion is the only structural change between the two years. Groups that fell in the lower bracket in 2025 because their revenue was close to the old threshold must verify whether they remain in scope for 2026.

The following actions should be completed before 15 December 2026:

• Confirm exposure: verify that consolidated worldwide revenue for 2026 does or does not exceed €1.5 billion. A significant change in activity can alter the position.
• Calculate the average IS: extract the final 2025 IS from the filed tax return and build a documented 2026 IS projection.
• Model the CEBGE: run at least two scenarios — central and downside — to bracket the underestimation risk.
• Provision on the balance sheet: recognise the CEBGE charge at the half-year or quarterly close to avoid a sudden hit to the year-end result.
• Coordinate with the group parent (for subsidiaries of international groups): obtain confirmation of the consolidated worldwide revenue figure and instructions on how the contribution will be allocated internally.
• Revise the cash-flow forecast: incorporate the December outflow into the liquidity plan, ideally from September onwards.
• Review the tax-consolidation perimeter: any entry or exit from the group in 2025–2026 may affect the average IS base.
• Prepare the reporting form: check with DGFiP the final filing requirements for the 2026 CEBGE.

Our outsourced CFO service can support structures that do not have a dedicated internal tax function to manage this work.

The CEBGE 2026 is a temporary measure with concrete and immediate financial consequences. It sits within a constrained budgetary environment that the 2026 Finance Act outlines in full. The most exposed groups — consolidated revenue above €3 billion with a high average IS — face an additional tax charge of up to 41.2 % of their average IS. This is not an optional provision: it is a statutory filing and payment obligation.

Best practice is to open this file now, not in November. The earlier the modelling assumptions are set, the greater the room for manoeuvre on cash management.

This article is for information purposes only and does not constitute personalised tax advice. The precise calculation and filing requirements for the CEBGE may evolve through DGFiP guidance: consult a chartered accountant (expert-comptable) or tax lawyer before taking any consequential decision. Current as of 24 May 2026.