Corporate philanthropy now plays a central role in French economic and social life. Far from being the preserve of large corporations, it also involves SMEs and mid-cap companies, which use this approach both to demonstrate their social responsibility and to benefit from attractive tax incentives. In 2024, the Philanthropy Barometer estimated that nearly 3 billion euros in donations had been made by French companies, with a growing proportion coming from medium-sized organisations.

But beyond the figures, it is still essential to have a clear understanding of the legal and tax framework governing corporate philanthropy, in order to maximise its benefits and avoid the risk of a tax reassessment.

What is corporate sponsorship?

The General Tax Code (Article 238 bis) defines patronage as material support provided without any consideration to a cause or organisation serving the public interest. Unlike sponsorship, patronage does not aim to generate a direct commercial return, but may nevertheless enhance the image of the sponsoring company.

There are various forms of patronage:

• In cash: a direct financial donation;

• In kind: the provision of assets (premises, equipment, works of art, products);

• Skills provision: the secondment of employees during their working hours.

Eligible beneficiary organisations

For a donation to qualify for a tax relief, it must be made to an organisation that meets certain conditions:

• Charities or organisations serving the public interest in the fields of philanthropy, education, science, social welfare, humanitarian aid, sport, family life or culture;

• Charities or associations recognised as being of public benefit;

• Endowment fund;

• Approved organisations located in the European Union or in a country that has concluded a tax treaty with France containing a provision on administrative assistance.

Organisations must be able to issue a valid tax receipt under their own responsibility.

The applicable tax regime

Sponsorship entitles the donor to a corporate tax relief:

• 60 % of the donation amount, up to a limit of 0.5 % of the company’s turnover excluding VAT or €20,000 per year, whichever is more favourable.

• For annual donations exceeding 2 million euros, the tax relief rate is reduced to 40 % (subject to certain exceptions, notably for donations to certain organisations providing assistance to people in need).

Any unused surplus from donations may be carried forward to the following five financial years.

Counterparties: an area requiring vigilance

Sponsorship must be provided without any direct consideration in return. However, certain symbolic forms of consideration are permitted, provided their value is proportionate to the donation (for example, the inclusion of the sponsor’s logo).

Where the consideration becomes predominant (significant advertising exposure, direct commercial benefits), the transaction may be reclassified as sponsorship. In this case, the expenditure is deductible from the company’s taxable profit, but does not qualify for the tax relief for charitable giving.

A scheme under increased scrutiny

Corporate philanthropy remains a key public policy issue. The tax credit for charitable giving represents an annual cost of around 1.3 billion euros to the State, making it a scheme that is regularly scrutinised by the Court of Auditors and Parliament.

The tax authorities have stepped up their monitoring in recent years to prevent abuse:

• Fictitious or irregular receipts,

• Donations disguised as sponsorship,

• Inappropriate valuation of donations in kind.

Un manquement peut entraîner la remise en cause de la réduction d’impôt et des pénalités lourdes.

Conclusion

Corporate philanthropy is a powerful tax and strategic tool, provided that the specific rules laid down by the legislator are followed. For businesses, it offers a twofold benefit: supporting causes of public interest whilst optimising their tax position. However, it is also important to ensure the process is sound, by verifying that beneficiaries comply with the rules, ensuring donations are properly accounted for, and retaining supporting documentation.

Chez Qualifisc, nous accompagnons les entreprises dans la mise en place et la sécurisation de leurs dispositifs de mécénat, de la stratégie fiscale à la gestion des contrôles éventuels.