The French Government introduced as part of its bill for growth
and activity (Projet de loi pour la croissance et
l'activité, or Projet de loi Macron,
Macron Draft Law) a new measure aiming at boosting
industrial investment in France: an exceptional additional 40
percent depreciation of certain industrial assets
Under this new measure, companies are allowed an exceptional
deduction from their taxable income, equal to 40 percent of the
acquisition cost (excluding financial expenses) of certain eligible
The Exceptional Depreciation applies to assets that (i) have been
acquired or manufactured by companies between April 15, 2015, and
April 14, 2016, (ii) are eligible for declining-balance
depreciation, and (iii) fall into one of the categories set out in
the Macron Draft Law, including inter alia equipment and
tools used for industrial manufacturing operations or scientific
and technical research purposes.
In their official guidelines published on April 21, 2015, the FTA
specified that software that forms an indivisible whole with the
eligible assets set out in the Macron Draft Law, or that
contributes to the industrial manufacturing operations (e.g. design
or maintenance software), can be also eligible for the Exceptional
The Exceptional Depreciation will not be reflected under the
French GAAP and will take the form of a tax adjustment to book
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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