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French Bonus Tax: Enactment of the French Payroll Tax on Certain Bonuses Paid by Financial Institutions

Sullivan & Cromwell LLP - March 10, 2010

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This memorandum follows our publication of January 25, 2010 entitled “Proposed Legislation on French Bonus Tax” regarding the 50% tax on bonuses granted with respect to tax year 2009 by certain financial institutions operating in France. The proposed legislation was enacted on March 9, 2010. An amendment voted by the French Parliament resulted in the extension of the scope of the tax to heads of trading floor and trading desk operations (“directeur de salles de marchés” and “responsables de desks”). Various uncertainties remain as to the territorial scope of the tax and the activities that are subject to the tax.