The CFC rules requires, under some circumstances, the taxation in France, in the hands of a  French corporation, of the profits of a foreign entity which it owns.There are both control and low taxation threshold requirements : - a French corporation falls within the scope of CFC if it owns directly or indirectly more than 50 per cent of the share or voting rights of a foreign entity (company, subsidiary, branches, trust or comparable entities) ;  This threshold is reduced to 5% when more than 50% of the shares, shares, financial rights or voting rights of the legal entity established or incorporated outside France are held by companies established in France which act in concert, when the foreign entity is listed on a regulated market, or by companies that are directly or indirectly placed in a situation of control or dependence with respect to the legal person established in France and the foreign entity benefits from a preferential tax regime in the foreign State. An entity is considered to benefit from a preferential tax regime if it is not taxable in that State or taxable at a level that is less than 40% or more than it would have paid under the french law if it had been located in France (the threshold of 40 % aplies from the 1st of 2020, before that date the 50 % threshold aplies. 