TERRA PROMOTION
ARTICLE 244 QUATER W — FRENCH TAX CODE

The tax credit for productive investment in overseas territories (CIOP)

Tax credit for new productive investments in French overseas departments

THE SCHEME

What the law says

The CIOP is a tax credit for new productive investments made in French overseas departments, including Guadeloupe.

CGI art. 244 quater W

It benefits the company operating the investment, subject to tax under the réel regime.

BOI-BIC-RICI-10-160-10, § 20

The investment must be operated exclusively in a French overseas department.

BOI-BIC-RICI-10-160-10, § 60

Rate: 35% for a company subject to corporate tax; 38.25% for a company subject to income tax, in Guadeloupe.

BOI-BIC-RICI-10-160-20, § 110 and § 130

Base: the cost price of the investment recorded on the balance sheet, net of taxes, fees and public subsidies.

BOI-BIC-RICI-10-160-20, § 10

For a building under construction, the credit is acquired in instalments: 70% on completion of foundations, 20% on roofing, the balance on delivery.

BOI-BIC-RICI-10-160-20, § 150

Assignment and operating period: 15 years for building construction.

BOI-BIC-RICI-10-160-40, § 7

Prior administrative approval required for investments exceeding €1,000,000.

BOI-BIC-RICI-10-160-40, § 90

VERIFIED ON A CASE-BY-CASE BASIS

Conditions to validate per project

  • —Eligibility of the activity actually operated
  • —Base retained (cost price net of taxes, fees and public subsidies)
  • —Requirement for and obtention of prior approval

Tax credit under article 244 quater W of the French General Tax Code. Its benefit is subject to compliance with legal conditions, including operation and, where applicable, prior approval; each project is assessed on a case-by-case basis.

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The overseas productive investment tax credit (CIOP) | TERRA