Qualifying shareholdings benefit from the parent-subsidiary regime, which taxes dividends at a reduced corporate tax rate of 1.25%. This classification requires a long-term holding and effective influence over the issuing company, generally characterized by a stake of at least 5% of the share capital.

The withholding tax rate on dividends paid to a non-resident beneficiary in a cooperative state is generally reduced by tax treaties to between 5% and 15%. Without a treaty, the standard rate is 12.8%.

Article 38-6 of the CGI requires mark-to-market valuation at each fiscal year-end, with valuation differences included in taxable income. This leads to taxation of unrealized gains before actual collection, creating a potentially significant cash flow mismatch.

Accrued interest between the last coupon date and the fiscal year-end must be recognized and taxed as financial income, even if it will not be collected until later. This applies to bonds, where bond income is fully subject to the 25% corporate tax rate.

Symmetrical positions are subject to an anti-abuse regime that neutralizes the deduction of losses up to the amount of unrealized gains on offsetting positions. Therefore, losses cannot always be deducted immediately.

The deductibility of financial charges is limited to 30% of fiscal EBITDA or 3 million euros. Excess charges are not immediately deductible but can be carried forward to subsequent fiscal years. The calculation therefore involves EBITDA, the amount of financial charges, and carryforward rules.

The EU Parent-Subsidiary Directive eliminates all withholding tax on distributions to a European parent company holding at least 10% of the share capital for a minimum of two years. This optimizes international flows by reducing tax costs.

Redemption premiums are subject to actuarial spreading over the remaining life of the security for credit institutions and insurance companies. They are not taxed immediately but spread over time, unlike interest which is taxed at the time of recognition.