General tax on polluting activities (TGAP)

Verified 17 April 2026 - Entreprendre Public Service / Directorate of Legal and Administrative Information (Prime Minister), Ministry of Finance

The general tax on polluting activities (TGAP) must be paid by companies with a polluting activity or using polluting products.

In particular, it consists of the following components: waste landfilled (dangerous and non-dangerous), emission of polluting substances, laundry detergents, auxiliary washing preparations, fabric softeners or fabric softeners and extraction materials. Its amount varies according to the activity and the product.

To note: the TGAP on fuels has become the TIRUERT and concerns professionals making fuels available (oil depots, oil refiners).

TGAP on landfilled waste

The landfill component of the TGAP is applicable to waste storage or treatment facilities and companies that transfer waste to another jurisdiction.

Hazardous and non-hazardous waste

The component of waste landfilled applies to all waste dangerous and non-dangerous not being exempted.

Exemption for recovered waste

Material recovery

The TGAP does not apply waste subject to a valuation material : reuse, recycling, organic recovery (return to the soil after composting or after methanization), backfillingetc.

Hazardous residues from the recovery of material from the treatment of polluted land

The TGAP does not apply to facilities for the storage of hazardous waste, residues resulting from waste treatment, where the following cumulative conditions are met:

  • The installation of storage of residues and that of waste treatment from which they originate are located on the same right-of-way.
  • This is about hazardous waste of the following categories:
    • Drilling mud and other drilling waste, except fresh water
    • Sludge from soil decontamination
    • Land, including spoil from contaminated sites, pebbles and dredged sludge
    • Sanding waste from wastewater treatment plants
    • Minerals, e.g. sand or pebbles, constituting waste from the mechanical treatment of waste, e.g. sorting, grinding, compacting or granulation
    • Land and stones that constitute waste from gardens and parks
  • The waste treatment plant shall have the following characteristics:
    • The installation shall not emit into the atmosphere polluting substances above the thresholds for subjection the pollutant emissions component of the TGAP.
    • The mass of waste which has undergone material recovery during the calendar year must represent at least 70 of all the waste received by the treatment plant during the same period. 

FYI  

A regulatory text specifying the thresholds is expected following the modification of this exemption by the 2026 Finance Law.

Exemption of certain waste

There are 4 types of waste exempted from the TGAP on landfill waste, which are as follows:

  • Waste that meets all of the following conditions:
    • does not undergo any significant physical, chemical or biological changes
    • does not decompose
    • don't burn
    • does not produce any physical or chemical reaction
    • is not biodegradable
    • and does not deteriorate the materials with which it comes into contact in a manner likely to cause harm to the environment or human health.
  • The waste of construction and insulation materials containing asbestos as well as waste personal protective equipment (PPE) and collective protective devices polluted by asbestos fibers.
  • The waste from separate collection or sorting where material recovery is prohibited or disposal is compulsory, except where it has been intentionally mixed subsequently with waste which does not satisfy that condition. A ministerial order will determine the categories of waste concerned.
  • The waste component of the TGAP does not apply to waste arising from exceptional or irregular events. This is waste:
    • Generated by a natural disaster, the condition of which is determined by decree. This also applies to natural disasters outside France (metropolitan France, overseas departments and regions (Drom), Monaco). In order to benefit from the exemption, waste must be received or transferred between the start of the claim and 240 days after the end date of the claim.
    • Originating from abandoned unauthorized deposits whose producers cannot be identified, recorded by prefectural order. The depots concerned must have been abandoned by one or more persons on one or more parcels of land glued together. Their estimated quantity must:
      • Exceeding 100 tons
      • Exceeding 50 tons, after sorting of waste which can be recovered or extended producer responsibility.
    • From deposits within 100 meters of the shoreline in an erosion-prone area or potential marine flooding area. A list of the repositories concerned is available in an order.

FYI  

A regulatory text is expected following the modification of this exemption by the 2026 Finance Law.

Exemption of certain hazardous and non-hazardous wastes

The hazardous waste from heat treatment waste which has been the subject of a type-approval subject to the tax on incinerated waste or an equivalent measure in a foreigner territory are also exempt from the TGAP.

The non-hazardous waste meeting the following cumulative conditions are exempt from TGAP:

  • The waste is extract of solid materials from the heat treatment of waste which has been type-approved subject to tax on incinerated waste or an equivalent measure in a foreigner territory.
  • Lthe technical impossibility of any valuation non-hazardous waste.

Relevant facilities and operations

The component of the TGAP on landfilled waste shall be paid by the companies for each waste involved in any of the following activities:

  • Receipt of waste in an installation classified for the protection of the environment (ICPE) for storage or heat treatment of waste subject to authorization (headings 2720-1, 2720-2, 2760-1, 2760-2 of ICPE nomenclature)
  • Transfer of waste to another State for reception in a waste storage or heat treatment facility subject to local authorization.

The TGAP must be paid by, respectively:

  • The operator of the facility for the storage or heat treatment of waste subject to authorization: the person holding the operating authorization or the de facto operator
  • Companies who transfer or cause to be transferred waste from France to another state.

The ICPE storage or heat treatment of waste subject to registration or declaration are not affected by this component of the TGAP.

Territory concerned

The component of the TGAP on landfilled waste applies in the following territories :

  • Metropolitan France
  • Overseas Departments and Regions (Drom)
  • Monaco.

Please note

Shipments of waste from one of these territories subject to TGAP to another French territory not subject to this tax (for example New Caledonia) are subject to the waste component landfilled by TGAP. They are treated as shipments of waste to another State.

Exempted facilities and operations

Storage or storage facilities heat treatment of waste dangerous or not dangerous that they produce themselves are not subject to the component of the TGAP waste landfilled.

Industrial effluent injection plants

The TGAP does not apply to licensed industrial effluent injection facilities. This concerns exclusively the injection of industrial effluents into the “Cretaceous 4000” geological structure, located in the Lacq region (Pyrénées-Atlantiques).

The amount of the TGAP component on landfilled waste is calculated through the mass, expressed in tons, waste received or transferred abroad.

As the TGAP is due per year, the waste considered must be accounted for by calendar year.

The tariff for the component of the TGAP on landfilled waste shall be determined on the basis of:

  • the hazardous nature of the waste (hazardous waste or non-hazardous waste)
  • of the calendar year
  • from 2027, indexation on inflation

The rates for 2026, 2027, 2028, 2029, 2030 are as follows:

Tableau - TGAP tariffs for landfilled waste (in euro/ton)

Rates in 2026

Rates in 2027

Rates in 2028

Rates in 2029

Rates in 2030

Not Dangerous

69

73

77

81

85

Dangerous

30.36

indexing

indexing

indexing

indexing

Please note

The rates shown apply to:

  • Companies that transfer waste to facilities located abroad
  • Operators of classified waste disposal facilities located in France (Metropolitan France, Drom, Monaco) which receive waste.

In some cases, there is a increased rate, i.e. a tariff higher than the normal tariff.

The increased rates are as follows:

  • For the year 2026, the tariff is increased by €200 per ton in case ofirregular operation.
  • For waste received in a facility classified as authorized for the storage of non-hazardous waste and which treats household or similar waste, the tariff may be increased by a maximum €2 per ton. The amount of this increase is determined by the municipality or, in the case of an installation located on the territory of several municipalities, the increase is determined by the corresponding deliberations of their municipal councils before 14 October of the previous year.

In some cases, there is a discounted rate, i.e. a lower rate than the normal rate.

The reduced rates are as follows:

  • In case of receipt of non-hazardous waste in French Guiana in a facility that is not accessible by land, the rate is set at €3 per ton.
  • For the non-hazardous waste approved for storage in an ICPE or transferred to a facility located in another State from the Corsica, the normal rate shall be reduced by 20%.
  • For the non-hazardous waste approved for storage in an ICPE or transferred to a facility located in another State from Drom, the normal rate shall be reduced by a proportion of 20% and 80%. This proportion is determined by ministerial decree according to the scale of the eligible investments underway or committed to the sorting or recovery of waste. The department of Mayotte benefit from exemption from the normal tariff on non-hazardous waste.

Warning  

Pending a ministerial order, the former reduced rates are as follows:

  • Guadeloupe, Martinique and Reunion : 35%
  • French Guiana : 75%
  • Mayotte : exemption from the standard tariff on non-hazardous waste.

All components of the PAAT must be reported and paid by calendar year. The procedures are the same for the 4 components. They must be reported and paid at the same time.

The PGRT that must be paid for a given calendar year is paid by the persons liable in the form of a single annual advance payment. This deposit must be paid spontaneously each year the TGAP is due. A regularization is carried out the following year.

The deposit and the regularization of the TGAP are payable only online. The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE) (the Foreign company Tax Service (SIE) is available at the same link):

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE):
Who shall I contact

Payment and reporting depend on the company's tax system.

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Simplified taxation system

The simplified tax regime concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 24 October of the year in which the tax is due. Example: October 23, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized at the latest:

  • Where the accounting year coincides with the calendar year, the second day workmanlike that follows 1er May the year following the year for which the tax is to be paid. Example: No later than May 4, 2026 for the TGAP due for 2025.
  • Where the accounting year does not coincide with the calendar year, within 3 months of the end of this financial year. Example: No later than September 30, 2026 for the TGAP due for the accounting year 1er July 2025 to June 30, 2026.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the 2 amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Normal real taxation regime

The standard tax regime applies to companies whose annual turnover excluding tax is greater than:

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit between 15 and 24 October of the year in which the tax is due. Example: between October 15 and 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized:

  • Either between 15 and 24 May of the year following that for which tax is to be paid for persons liable under monthly normal actual plan. Example: between May 15 and 24, 2026 for the TGAP due for the year 2025.
  • Either between 15 and 24 April of the year following that for which tax is to be paid for persons liable under quarterly normal real plan. Example: between April 15 and 24, 2026 for the TGAP due for the year 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Other tax regimes

Companies which are not subject to the ordinary real system of taxation or to the simplified system of taxation are affected by this situation. These include the following companies:

  • Companies subject to the exemption from VAT
  • Companies not identified for VAT purposes in France.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 25 October of the year in which the tax is due. Example: October 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

TGAP must be reported and regularized no later than 25 April the year following the year for which the tax is to be paid. Example: No later than April 25, 2026 for the TGAP due for 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

The persons liable for payment of the TGAP must keep all the relevant supporting documents to justify the information indicated on the declaration.

These elements must be communicated as of the 1è request from the administration.

Keeping a record

Each company paying the TGAP on waste must keep detailed accounts of the waste it manages that is subject to this tax. It takes the form of a register. This register must detail, for each delivery of waste, the following:

  • Tonnage and nature of waste
  • Method of treatment
  • Place of provenance and identity of the producer
  • Date of receipt
  • Name of carrier
  • The registration number of the road vehicle that made the delivery.

Upon request, this information shall be provided to the control officers of the TGAP (Customs) component.

The exempted waste of the waste component of the TGAP shall be subject to a specific accounting, which distinguishes them according to their nature and the reason for exemption.

FYI  

A regulatory text is expected following the modification of this exemption by the 2026 Finance Law.

Obligations related to the invoicing of the TGAP component on landfilled waste

Companies paying for the landfill waste component of the TGAP pass on the tax paid in contracts concluded with the persons from whom they receive the waste. As the passing-on of the TGAP component is mandatory, the contracts concluded must include a clause expressly providing for the passing-on of the tax.

They send a copy of the figures to those persons each year the following used to prepare their tax return to the tax authority:

  • TGAP Waste Component Tariffs Applied
  • Tonnage of waste received allocated to each tariff of the TGAP component applied.

Please note

Where not all waste is subject to the same tax regime, it may be difficult to determine the specific pass-through for each waste provider.

The operator may calculate an overall amount to be passed on to the installation. It must then pass on that sum in proportion to the quantity of waste brought in by each contributor.

Specific obligation for hazardous waste storage facilities

One description of the site on which the hazardous waste storage facility is established:

  • Before they are put into operation, for new installations
  • Every year, for existing facilities.

This document shall include:

  • A topographic survey
  • Measurements of the density of the waste in sufficient numbers to enable the tonnage of the waste stored to be evaluated.

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Cessation of activity

In the event of a cessation of activity, in particular a judicial reorganization or liquidation, the TGAP declaration must be filed within one of the following deadlines:

  • 30 days, for companies subject to the ordinary real taxation regime
  • That is 60 days for companies subject to the simplified real tax regime or in other cases.

The simplified regime of taxation concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

The normal diet of taxation concerns companies whose annual turnover excluding tax is greater than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

This date shall be determined from the date of cessation registered at the Registry of the Commercial Court:

  • Or the location of the establishment
  • The location of the tax representative designated by the foreign business
  • Or, failing that, the place of the centers of main interests (the place of the central administration of that business).

The TGAP declaration is made via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The declaration must be accompanied by payment of the TGAP due for the year of cessation of activity.

No advance payment is due in the event of total cessation of activity before the deadline for declaration of the advance payment.

The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE)

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE)
Who shall I contact

Please note

The regularization normally applies when the cessation of activity occurs between the date of payment of the deposit and that of the filing of the declaration.

Fusion-absorption

The procedure to be followed depends on:

  • Date of merger-absorption
  • Whether the absorbing business was itself liable for the TGAP before the merger-absorption operation.
Absorbent business liable for the TGAP before merger-absorption
Mergers and acquisitions between 1 January and the date of filing of the TGAP declaration

The absorbent business transmits a annual declaration of joint TGAP covering the activity of the 2 businesses over the previous year.

The amount of the TGAP calculated for the previous year relating to the activity of the absorbed business shall be added to that of the absorbing business.

In its annual statement for the TGAP of the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Business A absorbed business B. The merger-absorption took place on 2 February 2024.

Business A is subject to the quarterly standard real regime. It must therefore pay the TGAP between 15 and 24 April.

The TGAP for the year 2023 is paid between 15 and 24 April 2024 by business A. Its amount is calculated and paid from the activity of businesses A and B in 2023.

The TGAP for the year 2024 will be paid between April 15 and 24, 2025 by business A. Its amount will be calculated and paid from the activity of business A during 2024, added to the activity of business B preceding the merger, from January 1 to February 2, 2024.

Merger-absorption between the filing date of TGAP's return and 31 December

The business absorbed paid the TGAP relating to its activities for the previous year.

The absorbing business paid the TGAP relating to its activities for the previous year.

In its annual declaration for the TGAP for the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Businesses A and B are subject to the quarterly standard actual regime. They must therefore pay the TGAP between 15 and 24 April.

Business A absorbed business B. The merger-absorption took place on 2 September 2023.

The TGAP for the year 2022 was paid between April 15 and 24, 2023 by each of businesses A and B for their respective activities.

The TGAP for the year 2023 will be paid between April 15 and 24, 2024 by business A. Its amount will be calculated and paid from the activity of business A during 2023, added to the activity of business B preceding the merger, from January 1 to September 2, 2023.

Absorbent business not liable for TGAP before merger-absorption

The absorbent business transmits a TGAP's annual declaration of the activity of the business absorbed during the previous year.

The amount of the APGT is calculated and paid in respect of the previous year by the absorbing business.

The absorbing business will have to make an annual declaration for the TGAP of the year following that of the merger, taking into account the activity of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Business A is not subject to the payment of the TGAP for its activities occurring before the merger-absorption.

Business B is subject to the payment of TGAP for its activities occurring before the merger-absorption.

Business A absorbed business B. The merger-absorption took place on 2 September 2023. Business A is subject to the TGAP as of September 2, 2023, following the merger.

The TGAP for 2023 will be paid in 2024 by business A. Its amount will be calculated and paid from the activity of business B preceding the merger, from January 1 to September 2, 2023, added to the activity of business A since September 2, 2023.

TGAP polluting emissions

The pollutant emissions component of the TGAP applies to facilities classified for environmental protection (ICPE) subject to registration or authorization which emit polluting substances.

Products concerned

The component of the TGAP on pollutant emissions concerns the following substances:

  • Sulfur oxides and other sulfur compounds
  • Nitrogen oxide and other oxygenated nitrogen compounds (except nitrous oxide) generated by combustion plants for any type of fuel or by industrial processes
  • Nitrous oxide
  • Hydrochloric acid
  • Non-methane hydrocarbons, solvents and other volatile organic compounds
  • Benzene
  • Polycyclic aromatic hydrocarbons (so-called PAH 4): benzo[a]pyrene, benzo[b]fluoranthene, benzo[k]fluoranthene and indeno[1,2,3-cd]pyrene
  • Arsenic
  • Mercury
  • Selenium
  • Lead
  • Zinc
  • Chromium
  • Copper
  • Nickel
  • Cadmium
  • Vanadium
  • Total suspended dust released into the atmosphere through devices designed to remove it: particles with a diameter of between 2.5 and 10 micrometers (called PM 10) and particles with a diameter of less than 2.5 micrometers (called PM 2.5).

Installations concerned

The pollutant emissions component of the TGAP is relevant to each facility classified for environmental protection (ICPE) subject to registration or authorization which fulfills at least one of the following conditions :

  • Combustion plant of maximum heat output 20 megawatts (MW) or more
  • Heat treatment plant for household waste with a treatment capacity of at least 3 tons per hour
  • A facility whose annual emission threshold exceeds at least one threshold for being subject to the pollutant emissions component of the TGAP.
Tableau - Thresholds to be subject to the pollutant emissions component of the TGAP

Polluting substance emitted into the atmosphere

Threshold of liability (per year)

Sulfur oxides and other sulfur compounds

150 tons

Nitrogen oxides and other oxygen compounds of nitrogen (except nitrous oxide)

150 tons

Nitrous oxide

150 tons

Hydrochloric acid

150 tons

Non-methane hydrocarbons, solvents and other volatile organic compounds

150 tons

Total suspended dust

5 tons

Benzene

1,000 kg

Polycyclic aromatic hydrocarbons (PAH 4)

50 kg

Arsenic

20 kg

Mercury

10 kg

Selenium

20 kg

Lead

200 kg

Zinc

200 kg

Chromium

100 kg

Copper

100 kg

Nickel

50 kg

Cadmium

10 kg

Vanadium

10 kg

Please note

With the exception of suspended dust, all related equipment or installations (other than combustion or heat treatment plants for household waste) that contribute to emissions of substances into the atmosphere shall be considered.

In the case of suspended dust, only those emitted via devices designed for its removal shall be considered.

Facilities excluded

Some facilities are not submitted the pollutant emissions component of the TGAP, although they meet the criteria indicated. These are the following:

  • Storage or heat treatment facilities exclusively used for waste generated by the operator
  • Industrial effluent injection facilities authorized in the geological structure called Crétace 4000 in the Lacq region (Pyrénées-Atlantiques).

The TGAP on pollutant emissions must be paid for the emissions of certain pollutant substances in France.

Emission of polluting substances

The tax is payable by the operators offacilities classified for environmental protection (ICPE) concerned by the pollutant emissions component of the TGAP.

It is due when polluting substances are emitted into the atmosphere by the installations concerned.

Territory subject to the TGAP

The pollutant emission component of the TGAP applies to installations located in France (metropolitan France, overseas departments and regions (Drom), Monaco).

Tariffs for the pollutant emissions component of the TGAP

The amount of the pollutant emissions component of the TGAP is calculated using the mass, expressed in tons or kilograms, substances emitted into the atmosphere by the installations concerned. As the TGAP is due per year, the substances considered must be accounted for by calendar year.

Its rate depends on the substances and the type of installation considered:

  • For combustion and household waste treatment plants subject to the TGAP, account shall be taken of the total mass of emissions for each taxable substance, with the exception of total suspended dust. These are taxable only if the threshold of 5 tons per year is exceeded.
  • For other installations, consideration shall be given the total mass of emissions of only those substances for which the threshold for subjection is exceeded. For each substance exceeding the threshold for attachment, the amount of the PGRT is calculated by taking into account the total mass of substance emitted by the facility.

For the calculation of the APTT amount, each substance is considered separately. If the threshold for liability is exceeded, the PGRT is payable.

Please note

The mass of nitrogen oxides and other oxygen compounds of nitrogen is, except for nitrous oxide, expressed in nitrogen dioxide equivalent. It corresponds to the sum of the ratio of mixture by volume (ppbv) of nitrogen monoxide (nitric oxide) and nitrogen dioxide, expressed in units of concentration by mass of nitrogen dioxide (ug/m³).

The tariff for the pollutant emissions component of the TGAP is based on a scale published in the Official Bulletin of Public Finances - Taxation (Bofip).

Rates for 2025 are as follows:

Tableau - 2025 Tariff for the Pollutant Emissions Component of the TGAP

Polluting substance emitted into the atmosphere

Threshold of liability (per year)

Tariff

Sulfur oxides and other sulfur compounds

150 tons

€163.32 per ton

Nitrogen oxides and other oxygen compounds of nitrogen (except nitrous oxide)

150 tons

€197.14 per ton

Nitrous oxide

150 tons

€83.41 per ton

Hydrochloric acid

150 tons

€55.59 per ton

Non-methane hydrocarbons, solvents and other volatile organic compounds

150 tons

€163.32 per ton

Total suspended dust

5 tons

€312.05 per ton

Benzene

1,000 kg

€6.02 per kg

Polycyclic aromatic hydrocarbons (PAH 4)

50 kg

€60.05 per kg

Arsenic

20 kg

€600.4 per kg

Mercury

10 kg

€1200.77 per kg

Selenium

20 kg

€600.4 per kg

Lead

200 kg

€11.78 per kg

Zinc

200 kg

€5.89 per kg

Chromium

100 kg

€23.57 per kg

Copper

100 kg

€5.89 per kg

Nickel

50 kg

€117.84 per kg

Cadmium

10 kg

€589.21 per kg

Vanadium

10 kg

€5.89 per kg

Deduction of donations to approved oversight associations (AASQA)

Deductibility of the donation

The operator of a facility subject to the TGAP may deduct from the amount of the PAAT component due in respect of polluting emissions contributions or gifts of any kind to accredited air quality monitoring associations (AASQA).

This deduction shall apply where all of the following conditions are completed:

  • The operator is a member of the beneficiary AASQA.
  • The facility is located in the monitored area of the recipient AASQA.
  • Contributions or donations were made within 12 months of the deadline for filing the TGAP return.

Donations made in kind are deductible only in the case of donations of equipment useful for measuring air quality. The deductible value of the gift is calculated on the basis of the minimum of the carrying amount of the material or the actual market value if it is lower.

Maximum limit for deduction of donation

For each calendar year for which the PGRT component is reported and for each facility, the deduction may not exceed the greater of:

  • Either the sum of €171,000, within the limit of the amount of the component of the TGAP due in respect of the emissions of that installation before deduction
  • Either 25% the amount of the component of the TGAP due in respect of emissions from that installation before deduction.
Implementation of the deduction

The deduction is made on the return filed in respect of a particular year in which tax is payable, if the gifts are paid during the 12 months preceding the deadline for the submission of that declaration.

As such, surplus donations cannot be deducted from the PAAT payment for a future year, as the donation will then be more than 12 months before the deadline for filing the PAAT return.

The deduction can also be made on the advance of the component of the APGT that the operator must pay in October. This applies only if the donation is made before the deposit is paid and occurs within 12 months before the deadline for filing the return. The operator may take into account the contributions and gifts that it expects to make before the filing of the declaration.

All components of the PAAT must be reported and paid by calendar year. The procedures are the same for the 4 components. They must be reported and paid at the same time.

The PGRT that must be paid for a given calendar year is paid by the persons liable in the form of a single annual advance. This deposit must be paid spontaneously each year the TGAP is due. A regularization is carried out the following year.

The deposit and the regularization of the TGAP are payable only online. The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE) (the Foreign company Tax Service (SIE) is available at the same link):

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE):
Who shall I contact

Payment and reporting depend on the company's tax system.

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Simplified taxation system

The simplified tax regime concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 24 October of the year in which the tax is due. Example: October 23, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized at the latest:

  • Where the accounting year coincides with the calendar year, the second day workmanlike that follows 1er May the year following the year for which the tax is to be paid. Example: No later than May 4, 2026 for the TGAP due for 2025.
  • Where the accounting year does not coincide with the calendar year, within 3 months of the end of this financial year. Example: No later than September 30, 2026 for the TGAP due for the accounting year 1er July 2025 to June 30, 2026.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the 2 amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Normal real taxation regime

The standard tax regime applies to companies whose annual turnover excluding tax is greater than:

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit between 15 and 24 October of the year in which the tax is due. Example: between October 15 and 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized:

  • Either between 15 and 24 May of the year following that for which tax is to be paid for persons liable under monthly normal actual plan. Example: between May 15 and 24, 2026 for the TGAP due for the year 2025.
  • Either between 15 and 24 April of the year following that for which tax is to be paid for persons liable under quarterly normal real plan. Example: between April 15 and 24, 2026 for the TGAP due for the year 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Other tax regimes

Companies which are not subject to the ordinary real system of taxation or to the simplified system of taxation are affected by this situation. These include the following companies:

  • Companies subject to the exemption from VAT
  • Companies not identified for VAT purposes in France.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 25 October of the year in which the tax is due. Example: October 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

TGAP must be reported and regularized no later than 25 April the year following the year for which the tax is to be paid. Example: No later than April 25, 2026 for the TGAP due for 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

The persons liable for payment of the TGAP must keep all the relevant supporting documents to justify the information indicated on the declaration.

These elements must be communicated as of the 1è request from the administration.

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Cessation of activity

In the event of a cessation of activity, in particular a judicial reorganization or liquidation, the TGAP declaration must be filed within one of the following deadlines:

  • 30 days, for companies subject to the ordinary real taxation regime
  • That is 60 days for companies subject to the simplified real tax regime or in other cases.

The simplified regime of taxation concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

The normal diet of taxation concerns companies whose annual turnover excluding tax is greater than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

This date shall be determined from the date of cessation registered at the Registry of the Commercial Court:

  • Or the location of the establishment
  • The location of the tax representative designated by the foreign business
  • Or, failing that, the place of the centers of main interests (the place of the central administration of that business).

The TGAP declaration is made via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The declaration must be accompanied by payment of the TGAP due for the year of cessation of activity.

No advance payment is due in the event of total cessation of activity before the deadline for declaration of the advance payment.

The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE)

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE)
Who shall I contact

Please note

The regularization normally applies when the cessation of activity occurs between the date of payment of the deposit and that of the filing of the declaration.

Fusion-absorption

The procedure to be followed depends on:

  • Date of merger-absorption
  • Whether the absorbing business was itself liable for the TGAP before the merger-absorption operation.
Absorbent business liable for the TGAP before merger-absorption
Mergers and acquisitions between 1 January and the date of filing of the TGAP declaration

The absorbent business transmits a annual declaration of joint TGAP covering the activity of the 2 businesses over the previous year.

The amount of the TGAP calculated for the previous year relating to the activity of the absorbed business shall be added to that of the absorbing business.

In its annual statement for the TGAP of the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Business A absorbed business B. The merger-absorption took place on 2 February 2024.

Business A is subject to the quarterly standard real regime. It must therefore pay the TGAP between 15 and 24 April.

The TGAP for the year 2023 is paid between 15 and 24 April 2024 by business A. Its amount is calculated and paid from the activity of businesses A and B in 2023.

The TGAP for the year 2024 will be paid between April 15 and 24, 2025 by business A. Its amount will be calculated and paid from the activity of business A during 2024, added to the activity of business B preceding the merger, from January 1 to February 2, 2024.

Merger-absorption between the filing date of TGAP's return and 31 December

The business absorbed paid the TGAP relating to its activities for the previous year.

The absorbing business paid the TGAP relating to its activities for the previous year.

In its annual declaration for the TGAP for the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Businesses A and B are subject to the quarterly standard actual regime. They must therefore pay the TGAP between 15 and 24 April.

Business A absorbed business B. The merger-absorption took place on 2 September 2023.

The TGAP for the year 2022 was paid between April 15 and 24, 2023 by each of businesses A and B for their respective activities.

The TGAP for the year 2023 will be paid between April 15 and 24, 2024 by business A. Its amount will be calculated and paid from the activity of business A during 2023, added to the activity of business B preceding the merger, from January 1 to September 2, 2023.

Absorbent business not liable for TGAP before merger-absorption

The absorbent business transmits a TGAP's annual declaration of the activity of the business absorbed during the previous year.

The amount of the APGT is calculated and paid in respect of the previous year by the absorbing business.

The absorbing business will have to make an annual declaration for the TGAP of the year following that of the merger, taking into account the activity of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Business A is not subject to the payment of the TGAP for its activities occurring before the merger-absorption.

Business B is subject to the payment of TGAP for its activities occurring before the merger-absorption.

Business A absorbed business B. The merger-absorption took place on 2 September 2023. Business A is subject to the TGAP as of September 2, 2023, following the merger.

The TGAP for 2023 will be paid in 2024 by business A. Its amount will be calculated and paid from the activity of business B preceding the merger, from January 1 to September 2, 2023, added to the activity of business A since September 2, 2023.

TGAP detergents

The laundry component of the TGAP is applicable to companies who make the first delivery or use of laundry detergents, auxiliary washing preparations, softeners or fabric softeners.

Products concerned

The component of the TGAP on laundry detergents, washing aids, softeners or fabric softeners concerns the following products:

  • Laundry preparations falling within the categories CN 3402 20 90 of the bill of materials for retail packaged products and CN 3402 90 90 for the others. These include:
    • Preparations based on surfactants (detergents): laundry detergents, dishwasher products, single-dose tablets
    • Auxiliary washing preparations used for soaking (pre-washing), rinsing or bleaching laundry, washing dishes and kitchen utensils
    • Dry cleaning products for washing laundry.
  • Softening or fabric softening agents falling within subheadings CN 3809 10 10 to 3809 91 00.

Excluded products

The following products are not affected through this component of the TGAP:

  • Cleaning preparations and products intended for the maintenance of floors, windows or any other surface which fall within one of the two subheadings CN 3402 20 90 and CN 3402 90 90 of the bill of materials. Where a product can be used as a laundry preparation or as a cleaning preparation, it shall only be taxed if the function of laundry preparation is the most important. If neither of the two functions is more decisive than the other, the product is not taxed.
  • Products under headings CN 3809 10 10 to CN 3809 91 00 which are intended for laundry but which have other functions (accelerators for dyeing, fixing dyes, etc.) or intended for other products (paper industry, leather industry, etc.).

Triggering the TGAP submission

First delivery or use

The tax is due by the company making the first delivery of taxable products or their first use.

Deliveries in which the products change ownership are the only ones concerned. They can take place free of charge (donations) or for a fee. The transport of the product without change of owner does not trigger the submission to the TGAP. Losses and thefts don't.

Territory subject to the TGAP

The country of origin of the product has no influence on the payment of the TGAP.

The detergent component of the TGAP is due when:

  • In case of transport or dispatch to the purchaser, the starting point is located in France (Metropolitan France, overseas departments and regions (Drom), Monaco), except in cases where the seller carries out or takes over the transport to the foreigner
  • In case of transport or dispatch to the purchaser, the starting point is located outside of France (Metropolitan France, Drom, Monaco), to France, in the context of a sale for a non-professional user
  • In the absence of transport or dispatch to the purchaser, the products are located in France (Metropolitan France, Drom, Monaco) at the time of delivery (change of owner)
  • When the products are located in France (Metropolitan France, Drom, Monaco) during their use.

When the same taxable product is delivered several times in France, only the first delivery is subject to the TGAP.

Suspension of the TGAP for certain exports

Conditions for suspension

There is a case where the payment of the extraction materials component of the TGAP can be suspended.

The 3 following conditions must be assembled, for each taxable product of each delivery :

  • Delivery is the first delivery in France.
  • This delivery is made for the benefit of a company that is destined for a shipment or transport outside France.
  • The beneficiary shall draw up, at the latest on the date of invoicing, a certificate stating the use of the suspension scheme and certifying that the product is intended to be dispatched or transported outside France.

The certificate must follow the following model:

Attestation model to benefit from the suspensive regime of the TGAP (extraction materials and detergents)

A single certificate can be created for all identical products delivered at the same time.

A single certificate may also be issued for all deliveries of identical products made in the same month between the same two companies. In this case, the certificate must be issued on the date of the last invoice for these deliveries.

In all cases, each certificate must be issued in 2 copies, one of which is kept by the beneficiary, and the other is given to the company transferring the materials.

End of suspension

The suspension of payment of the TGAP is valid as long as the products are intended for shipment or transport outside France. If this shipment or transport takes place, the TGAP does not have to be paid.

The suspension of the payment of the TGAP stops and the TGAP is due in the following cases :

  • Delivery by the beneficiary of the products when the places of departure and destination are located in France (Metropolitan France, Drom, Monaco)
  • Use of products in France (Metropolitan France, Drom, Monaco) by the beneficiary company
  • Assignment of the products to another use by the beneficiary
  • Modification of taxable products, including unpackaging or addition of other substances
  • An event that makes it impossible to ship or transport taxable products outside of France, such as the loss or destruction of the product.

Please note

The fact of suspending the payment of the TGAP does not change its tariff : the first delivery is always considered in the calculation of the amount to be paid.

For example, if the first delivery is not in the same year as the PGRT is paid, the amount payable will be calculated from the rate for the year of the first delivery.

The tariff for the TGAP component on laundry detergents is based on scale published in the Official Bulletin of Public Finances - Taxation (Bofip).

The amount of the TGAP component on laundry detergents is calculated using the mass, expressed in tons, of the products concerned. This is the net mass of products, excluding packaging and containers.

Its rate depends on the phosphate content of the products in question. This content is obtained by multiplying the phosphorus oxide content of the product by 1.73.

Its amount for 2025 is:

  • €50.79 per ton, for detergents with a phosphate content of less than 5% of weight
  • €218.81 per ton, for detergents with a phosphate content of between 5% and 30% of weight
  • €364.7 per ton, for detergents with a phosphate content greater than 30% weight.

All components of the PAAT must be reported and paid by calendar year. The procedures are the same for the 4 components. They must be reported and paid at the same time.

The PGRT that must be paid for a given calendar year is paid by the persons liable in the form of a single annual advance payment. This deposit must be paid spontaneously each year the TGAP is due. A regularization is carried out the following year.

The deposit and the regularization of the TGAP are payable only online. The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE) (the Foreign company Tax Service (SIE) is available at the same link):

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE):
Who shall I contact

Payment and reporting depend on the company's tax system.

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Simplified taxation system

The simplified tax regime concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 24 October of the year in which the tax is due. Example: October 23, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized at the latest:

  • Where the accounting year coincides with the calendar year, the second day workmanlike that follows 1er May the year following the year for which the tax is to be paid. Example: No later than May 4, 2026 for the TGAP due for 2025.
  • Where the accounting year does not coincide with the calendar year, within 3 months of the end of this financial year. Example: No later than September 30, 2026 for the TGAP due for the accounting year 1er July 2025 to June 30, 2026.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the 2 amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Normal real taxation regime

The standard tax regime applies to companies whose annual turnover excluding tax is greater than:

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit between 15 and 24 October of the year in which the tax is due. Example: between October 15 and 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized:

  • Either between 15 and 24 May of the year following that for which tax is to be paid for persons liable under monthly normal actual plan. Example: between May 15 and 24, 2026 for the TGAP due for the year 2025.
  • Either between 15 and 24 April of the year following that for which tax is to be paid for persons liable under quarterly normal real plan. Example: between April 15 and 24, 2026 for the TGAP due for the year 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Other tax regimes

Companies which are not subject to the ordinary real system of taxation or to the simplified system of taxation are affected by this situation. These include the following companies:

  • Companies subject to the exemption from VAT
  • Companies not identified for VAT purposes in France.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 25 October of the year in which the tax is due. Example: October 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

TGAP must be reported and regularized no later than 25 April the year following the year for which the tax is to be paid. Example: No later than April 25, 2026 for the TGAP due for 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

The persons liable for payment of the TGAP must keep all the relevant supporting documents to justify the information indicated on the declaration.

These elements must be communicated as of the 1è request from the administration.

Each company paying the TGAP on laundry detergents must keep detailed accounts of the products which it manages and which are subject to this tax. This accounting must detail monthly and for each set of identical products the following:

  • Quantities of taxed products, price list and amount of related tax
  • Quantities of goods subject to the PGAT that have been exempted from tax or delivered in suspension of tax. The amount of the tax that would have been applied to them in the absence of exemption or suspension must also be indicated.
  • Quantities of products subject to the TGAP and no longer available to taxpayers (e.g. losses, theft, transformation into other products, taxable products delivered but which had already been first delivered when they were acquired). The amount of the tax that would have been applied to them if they had been delivered for the first time must be indicated.
  • For the beneficiaries of the suspension scheme, quantities of products subject to the TGAP acquired under suspension of tax and the copy of the certificate which they have kept.

This information must be provided upon request to the control officers of the TGAP (Customs) component.

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Cessation of activity

In the event of a cessation of activity, in particular a judicial reorganization or liquidation, the TGAP declaration must be filed within one of the following deadlines:

  • 30 days, for companies subject to the ordinary real taxation regime
  • That is 60 days for companies subject to the simplified real tax regime or in other cases.

The simplified regime of taxation concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

The normal diet of taxation concerns companies whose annual turnover excluding tax is greater than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

This date shall be determined from the date of cessation registered at the Registry of the Commercial Court:

  • Or the location of the establishment
  • The location of the tax representative designated by the foreign business
  • Or, failing that, the place of the centers of main interests (the place of the central administration of that business).

The TGAP declaration is made via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The declaration must be accompanied by payment of the TGAP due for the year of cessation of activity.

No advance payment is due in the event of total cessation of activity before the deadline for declaration of the advance payment.

The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE)

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE)
Who shall I contact

Please note

The regularization normally applies when the cessation of activity occurs between the date of payment of the deposit and that of the filing of the declaration.

Fusion-absorption

The procedure to be followed depends on:

  • Date of merger-absorption
  • Whether the absorbing business was itself liable for the TGAP before the merger-absorption operation.
Absorbent business liable for the TGAP before merger-absorption
Mergers and acquisitions between 1 January and the date of filing of the TGAP declaration

The absorbent business transmits a annual declaration of joint TGAP covering the activity of the 2 businesses over the previous year.

The amount of the TGAP calculated for the previous year relating to the activity of the absorbed business shall be added to that of the absorbing business.

In its annual statement for the TGAP of the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Business A absorbed business B. The merger-absorption took place on 2 February 2024.

Business A is subject to the quarterly standard real regime. It must therefore pay the TGAP between 15 and 24 April.

The TGAP for the year 2023 is paid between 15 and 24 April 2024 by business A. Its amount is calculated and paid from the activity of businesses A and B in 2023.

The TGAP for the year 2024 will be paid between April 15 and 24, 2025 by business A. Its amount will be calculated and paid from the activity of business A during 2024, added to the activity of business B preceding the merger, from January 1 to February 2, 2024.

Merger-absorption between the filing date of TGAP's return and 31 December

The business absorbed paid the TGAP relating to its activities for the previous year.

The absorbing business paid the TGAP relating to its activities for the previous year.

In its annual declaration for the TGAP for the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Businesses A and B are subject to the quarterly standard actual regime. They must therefore pay the TGAP between 15 and 24 April.

Business A absorbed business B. The merger-absorption took place on 2 September 2023.

The TGAP for the year 2022 was paid between April 15 and 24, 2023 by each of businesses A and B for their respective activities.

The TGAP for the year 2023 will be paid between April 15 and 24, 2024 by business A. Its amount will be calculated and paid from the activity of business A during 2023, added to the activity of business B preceding the merger, from January 1 to September 2, 2023.

Absorbent business not liable for TGAP before merger-absorption

The absorbent business transmits a TGAP's annual declaration of the activity of the business absorbed during the previous year.

The amount of the APGT is calculated and paid in respect of the previous year by the absorbing business.

The absorbing business will have to make an annual declaration for the TGAP of the year following that of the merger, taking into account the activity of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Business A is not subject to the payment of the TGAP for its activities occurring before the merger-absorption.

Business B is subject to the payment of TGAP for its activities occurring before the merger-absorption.

Business A absorbed business B. The merger-absorption took place on 2 September 2023. Business A is subject to the TGAP as of September 2, 2023, following the merger.

The TGAP for 2023 will be paid in 2024 by business A. Its amount will be calculated and paid from the activity of business B preceding the merger, from January 1 to September 2, 2023, added to the activity of business A since September 2, 2023.

TGAP extraction materials

The extraction materials component of the TGAP is applicable to companies that make the first delivery or use of extraction materials (sand, pebbles, stones, etc.).

The component of the TGAP on extractive materials concerns materials that meet all of the following criteria :

  • The largest dimension material is less than 125 mm (mm) Where a lot includes materials that meet this size criterion and other materials that do not meet this size criterion, the tax shall apply to the part of the lot for which the criterion is met.
  • The method to obtain the material:
    • Either occurs naturally in the form of mineral grains
    • Either was obtained from crushed or fractionated rocks.
  • The material corresponds to one of the following codes of the bill of materials :
    • Natural Sands (CN 2505)
    • Pebbles, gravel and crushed stones (CN 2517 10)
    • Granules, chips and powder of various stones (CN 2517 41, CN 2517 49).
  • The material is used for (this is called the taxable uses):
    • Either the manufacture of the seat layers (which includes the foundation layer and the base layer) and surface (which includes the bonding layer and the tread layer), and laying ballasts, for building infrastructure of all kinds (roads, car parks, etc.), excluding the manufacture of the binder of asphalt
    • Either the making concrete, including the manufacture of concrete elements and excluding the manufacture of the binder (cement, bitumen, tar, clay, various mineral additions, etc.).
  • The material does not match to the following categories:
    • Material from recycling operations
    • Material composed of at least 97% silicon oxide (calculated content by mass, on a dry product).

Triggering the TGAP submission

First delivery or use

An extraction material becomes taxable as soon as it is used or intended for a taxable use, at the time of its first delivery or use in France.

Deliveries in which the materials change ownership are the only ones concerned. They can take place free of charge (donations) or for a fee. The transport of the material without change of ownership does not trigger submission to the TGAP.

The levy is payable by the company which makes the first supply of taxable extraction materials or their first use, in the context of a transaction subject to the TGAP.

The uses of taxable extraction materials are as follows:

  • Either the manufacture of the seat layers (which includes the foundation layer and the base layer) and surface (which includes the bonding layer and the tread layer), and laying ballasts, for building infrastructure of all kinds (roads, car parks, etc.), excluding the manufacture of the binder of asphalt
  • Either the making concrete, including the manufacture of concrete elements and excluding the manufacture of the binder (cement, bitumen, tar, clay, various mineral additions, etc.).
Territory subject to the TGAP

The extraction materials component of the TGAP is due when:

  • In case of transport or dispatch to the purchaser, the starting point is located in France (Metropolitan France, overseas departments and regions (Drom), Monaco), with the exception of cases where the seller carries out the transport to the foreigner and cases where the buyer pays the cost of delivery abroad
  • In case of transport or dispatch to the purchaser, the starting point is located outside of France (Metropolitan France, Drom, Monaco), to France, in the context of a sale for a non-professional user
  • In the absence of transport or dispatch to the purchaser, the materials are located in France (Metropolitan France, Drom, Monaco) at the time of delivery (change of owner)
  • The materials are located in France (Metropolitan France, Drom, Monaco) when using them.

When the same taxable product is delivered several times in France, only the first delivery is subject to TGAP.

The country of origin of the extraction material has no influence on the payment of the TGAP.

Materials of uncertain, unknown or undetermined use

A material with an uncertain, unknown, indeterminate or non-taxable use is not not subject to the TGAP.

It becomes so when it is used for taxable purposes.

Suspension of the TGAP for certain exports

Conditions for suspension

There is a case where the payment of the extraction materials component of the TGAP can be suspended.

The following 3 conditions must be met, for each taxable material of each delivery:

  • Delivery is the first delivery in France
  • This delivery is made for the benefit of a company that is destined for a shipment or transport outside France
  • The beneficiary shall establish, by the date of invoicing, a attestation mentioning the use of the suspension system and certifying that the product is intended to be dispatched or transported outside France.

The certificate must follow the following model:

Attestation model to benefit from the suspensive regime of the TGAP (extraction materials and detergents)

A single certificate can be created for all identical products delivered at the same time.

A single certificate may also be issued for all deliveries of identical products made in the same month between the same two companies. In this case, the certificate must be issued on the date of the last invoice for these deliveries.

In all cases, each certificate must be issued in 2 copies, one of which is kept by the beneficiary, and the other is given to the company transferring the materials.

End of suspension

The suspension of payment of the TGAP is valid as long as the materials are intended for shipment or transport outside France. If this shipment or transport takes place, the TGAP does not have to be paid.

The suspension of payment of the TGAP stops and the TGAP is due in the following cases:

  • Delivery by the beneficiary of the materials when the places of departure and destination are located in France (Metropolitan France, overseas departments and regions, Monaco)
  • Use of materials in France (Metropolitan France, overseas departments and regions, Monaco) by the beneficiary company
  • Assignment of materials to another use by the beneficiary
  • Modification of taxable products, in particular their unpackaging or the addition of binder
  • An event that makes it impossible to ship or transport taxable products outside of France, such as the loss or destruction of the product.

Please note

The fact of suspending the payment of the TGAP does not change its tariff : the first delivery is always considered in the calculation of the amount to be paid.

For example, if the first delivery is not in the same year as the PGRT is paid, the amount payable will be calculated from the rate for the year of the first delivery.

The tariff for the TGAP component on extractive materials is based on a scale published in the Official Bulletin of Public Finances - Taxation (Bofip).

The amount of the component of the TGAP on extraction materials is calculated through the mass, expressed in tons, of the products concerned. This is the net mass of products, excluding packaging and containers.

Its rate for 2025 is of €0.23 per ton.

All components of the PAAT must be reported and paid by calendar year. The procedures are the same for the 4 components. They must be reported and paid at the same time.

The PGRT that must be paid for a given calendar year is paid by the persons liable in the form of a single annual advance payment. This deposit must be paid spontaneously each year the TGAP is due. A regularization is carried out the following year.

The deposit and the regularization of the TGAP are payable only online. The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE) (the Foreign company Tax Service (SIE) is available at the same link):

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE):
Who shall I contact

Payment and reporting depend on the company's tax system.

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Simplified taxation system

The simplified tax regime concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 24 October of the year in which the tax is due. Example: October 23, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized at the latest:

  • Where the accounting year coincides with the calendar year, the second day workmanlike that follows 1er May the year following the year for which the tax is to be paid. Example: No later than May 4, 2026 for the TGAP due for 2025.
  • Where the accounting year does not coincide with the calendar year, within 3 months of the end of this financial year. Example: No later than September 30, 2026 for the PAAT due for the accounting year extending from 1er July 2025 to June 30, 2026.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the amount of the TGAP due for the same year, the company must pay the difference between the 2 amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Normal real taxation regime

The standard tax regime applies to companies whose annual turnover excluding tax is greater than:

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit between 15 and 24 October of the year in which the tax is due. Example: between October 15 and 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

The TGAP must be declared and regularized:

  • Either between 15 and 24 May of the year following that for which tax is to be paid for persons liable under monthly normal actual plan. Example: between May 15 and 24, 2026 for the TGAP due for the year 2025.
  • Either between 15 and 24 April of the year following that for which tax is to be paid for persons liable under quarterly normal real plan. Example: between April 15 and 24, 2026 for the TGAP due for the year 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

Other tax regimes

Companies which are not subject to the ordinary real system of taxation or to the simplified system of taxation are affected by this situation. These include the following companies:

  • Companies subject to the exemption from VAT
  • Companies not identified for VAT purposes in France.
Payment of the TGAP by deposit

The TGAP must be paid by a single deposit before 25 October of the year in which the tax is due. Example: October 24, 2026 for the TGAP due for the year 2026.

The amount of the deposit, for each component except the pollutant emission component, is equal to amount paid for the same component in the previous calendar year, increased in a proportion equal to growth rate of the consumer price index excluding tobacco of the penultimate year. This index is published by the National Institute of Statistics and Economic Studies (INSEE).

The consumer price index of all households in France for the whole excluding tobacco (2015 basis) for the year 2023 is 116.61. It was 111.24 in 2022. Its growth rate is therefore 4.83%.

In determining the amount of the advance payment for the pollutant emissions component, account shall be taken of the amount due in the previous year, before deduction of eligible contributions and grants.

Reporting and regularization of the TGAP the following year

TGAP must be reported and regularized no later than 25 April the year following the year for which the tax is to be paid. Example: No later than April 25, 2026 for the TGAP due for 2025.

The annual declaration of the TGAP is entered on the annual declaration of balance via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The TGAP's annual declaration must be accompanied by the regularization.

If the deposit paid is less than the PGRT amount due for the same year, the company must pay the difference between the two amounts.

If the deposit paid is greater than the PGRT amount due for the same year, the difference between the two amounts will be allocated to the upcoming deposit for the following year. On request from the tax authorities, this difference can be refunded.

The persons liable for payment of the TGAP must keep all the relevant supporting documents to justify the information indicated on the declaration.

These elements must be communicated as of the 1è request from the administration.

Each company paying the TGAP on extraction materials must keep detailed accounts of the materials it manages that are subject to this tax. This accounting must detail monthly and for each set of identical products the following:

  • Quantities of mined materials taxed, their tariff and the amount of the associated tax
  • Materials subject to TGAP but exempted due to their use
  • Quantities of materials subject to the TGAP that have been exempted from tax or delivered in suspension of tax. The amount of the tax that would have been applied to them in the absence of exemption or suspension must also be indicated.
  • Quantities of materials subject to the TGAP and no longer available to taxpayers (e.g. losses, theft, transformation into other products, taxable products delivered but which had already been first delivered when they were acquired). The amount of the tax that would have been applied to them if they had been delivered for the first time must be indicated.
  • For the beneficiaries of the suspension scheme, quantities of materials subject to the TGAP acquired under suspension of tax and the copy of the certificate that they have kept.

This information shall be provided to the control officers of the TGAP (Customs) component.

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Cessation of activity

In the event of a cessation of activity, in particular a judicial reorganization or liquidation, the TGAP declaration must be filed within one of the following deadlines:

  • 30 days, for companies subject to the ordinary real taxation regime
  • That is 60 days for companies subject to the simplified real tax regime or in other cases.

The simplified regime of taxation concerns companies whose annual turnover excluding tax is less than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

The normal diet of taxation concerns companies whose annual turnover excluding tax is greater than :

  • €945,000 for sales of goods, objects, supplies and foodstuffs to be taken away or consumed on the spot, provision of accommodation (excluding furnished rentals, furnished tourist accommodation, rural gîte and bed and breakfast)
  • €286,000 for service provision activities.

This date shall be determined from the date of cessation registered at the Registry of the Commercial Court:

  • Or the location of the establishment
  • The location of the tax representative designated by the foreign business
  • Or, failing that, the place of the centers of main interests (the place of the central administration of that business).

The TGAP declaration is made via this form:

TGAP Annual Declaration (Annual Tax on Polluting Activities)

Warning  

The declaration must be accompanied by payment of the TGAP due for the year of cessation of activity.

No advance payment is due in the event of total cessation of activity before the deadline for declaration of the advance payment.

The declaration shall be lodged with one of the following bodies to which the company is subject:

  • Company Tax Service (SIE)

Online tax account for professionals (EFI mode)

  • Major companies Directorate (DGE)
Who shall I contact

Please note

The regularization normally applies when the cessation of activity occurs between the date of payment of the deposit and that of the filing of the declaration.

Fusion-absorption

The procedure to be followed depends on:

  • Date of merger-absorption
  • Whether the absorbing business was itself liable for the TGAP before the merger-absorption operation.
Absorbent business liable for the TGAP before merger-absorption
Mergers and acquisitions between 1 January and the date of filing of the TGAP declaration

The absorbent business transmits a annual declaration of joint TGAP covering the activity of the 2 businesses over the previous year.

The amount of the TGAP calculated for the previous year relating to the activity of the absorbed business shall be added to that of the absorbing business.

In its annual statement for the TGAP of the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Business A absorbed business B. The merger-absorption took place on 2 February 2024.

Business A is subject to the quarterly standard real regime. It must therefore pay the TGAP between 15 and 24 April.

The TGAP for the year 2023 is paid between 15 and 24 April 2024 by business A. Its amount is calculated and paid from the activity of businesses A and B in 2023.

The TGAP for the year 2024 will be paid between April 15 and 24, 2025 by business A. Its amount will be calculated and paid from the activity of business A during 2024, added to the activity of business B preceding the merger, from January 1 to February 2, 2024.

Merger-absorption between the filing date of TGAP's return and 31 December

The business absorbed paid the TGAP relating to its activities for the previous year.

The absorbing business paid the TGAP relating to its activities for the previous year.

In its annual declaration for the TGAP for the year following the year of the merger, the absorbent business must add to its own activity that of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Businesses A and B are subject to payment of the TGAP.

Businesses A and B are subject to the quarterly standard actual regime. They must therefore pay the TGAP between 15 and 24 April.

Business A absorbed business B. The merger-absorption took place on 2 September 2023.

The TGAP for the year 2022 was paid between April 15 and 24, 2023 by each of businesses A and B for their respective activities.

The TGAP for the year 2023 will be paid between April 15 and 24, 2024 by business A. Its amount will be calculated and paid from the activity of business A during 2023, added to the activity of business B preceding the merger, from January 1 to September 2, 2023.

Absorbent business not liable for TGAP before merger-absorption

The absorbent business transmits a TGAP's annual declaration of the activity of the business absorbed during the previous year.

The amount of the APGT is calculated and paid in respect of the previous year by the absorbing business.

The absorbing business will have to make an annual declaration for the TGAP of the year following that of the merger, taking into account the activity of the absorbed business of 1er January of the previous year on the effective date of the merger.

Example :

Business A is not subject to the payment of the TGAP for its activities occurring before the merger-absorption.

Business B is subject to the payment of TGAP for its activities occurring before the merger-absorption.

Business A absorbed business B. The merger-absorption took place on 2 September 2023. Business A is subject to the TGAP as of September 2, 2023, following the merger.

The TGAP for 2023 will be paid in 2024 by business A. Its amount will be calculated and paid from the activity of business B preceding the merger, from January 1 to September 2, 2023, added to the activity of business A since September 2, 2023.

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