CFE and domiciliation: where do you really pay it, and how much?

It is one of the arguments most frequently put forward by domiciliation providers (companies that supply a registered office address): choosing your address supposedly lets you choose the commune in which your CFE (cotisation foncière des entreprises, the annual local business tax) is assessed, and therefore cut the bill. We prefer to say it plainly, even if it does not help the sale: it is untrue in the majority of cases. But there is an exception, and it concerns precisely a part of our client base.

The principle: CFE follows your premises, not your registered office

Article 1473 of the French tax code (“code général des impôts”, CGI) is unambiguous: the cotisation foncière des entreprises “is assessed in every commune where the taxpayer has premises or land, by reference to the rateable value (“valeur locative”) of the property situated there”.

In other words, the registered office stated in your articles is not, in itself, the place of assessment. A physiotherapist who rents a practice in Saint-Pierre-des-Corps and registers the office of the business in Tours pays CFE in Saint-Pierre-des-Corps, on the rateable value of the practice. The choice of registered office address changes nothing.

The same logic applies to corporation tax: article 218 A of the CGI assesses it “at the place of the main establishment”, and the tax authorities may instead use the place of effective management. Official guidance adds that assessment at the address of a domiciliation provider “may be accepted only where the taxpayer has no other business premises in which the activity or the management of the business is carried on”.

The exception that concerns many self-employed practitioners

That leaves the case of someone with no business premises at all. And it is far from marginal in the healthcare professions: the self-employed nurse who works exclusively in patients' homes, the physiotherapist who visits at home, the locum doctor working from colleagues' consulting rooms, the psychologist who only sees clients by video call.

For them, paragraph II of article 1647 D provides, and only where they have no premises or land, that “taxpayers holding an address under a commercial domiciliation agreement or another contractual arrangement are liable for the minimum charge (“cotisation minimum”) at the place of their domiciliation”.

In that configuration — and in that one alone — the domiciliation address becomes the place of assessment. It therefore has a real tax effect, since the minimum base is set by each commune within a statutory range, and the rate applied also varies from one commune to another.

How much: the 2026 minimum base bands

When CFE is calculated on the minimum charge, it no longer depends on a rateable value but on a base set by the commune, within a range that depends on your income. Here are the ranges in force in 2026:

Do not confuse the base with the tax. These figures are not what you will pay: they are taxable bases, to which the rate voted by the commune and its inter-municipal authority (“intercommunalité”) is then applied. A practitioner with 80 000 € of income in a commune that has set a base of 1 500 € will therefore pay that base multiplied by the local rate, not 1 500 €.

Note too the common floor: whatever the band, no commune may set a base below 250 €. Differences between communes do exist, but they concern modest sums — one more reason not to choose your domiciliation provider on that criterion alone.

The threshold that exempts you entirely

One rule deserves to be known by practitioners starting out or working on a secondary basis: taxpayers with turnover or income of 5 000 € or less are exempt from the minimum charge. The benefit of this exemption is subject to compliance with the European de minimis State aid rules.

The first two years: nothing, then half

This is the most useful relief, and the one most often forgotten in financial forecasts. A business is exempt from CFE in the year it is set up, until 31 December. The following year, its taxable base is reduced by 50%.

The trade-off is a filing obligation, and the deadline is strict: you must submit the 1447-C-SD return before 31 December of the year of incorporation. That document sets the assessment details for the following year — and it is also the route through which certain exemptions are claimed.

Two exemptions specific to the healthcare professions

The first is an automatic, permanent exemption, and it is remarkably little known among those it covers. Paragraph 5 of article 1460 of the CGI exempts midwives and gardes-malades (home nursing attendants) from CFE, except where they run a health centre (“maison de santé”), a maternity home or a convalescent home. No council resolution, no zoning application: the exemption simply applies.

The second is discretionary, and that is an essential distinction which many articles gloss over. Article 1464 D allows communes and inter-municipal authorities, by resolution, to exempt doctors, dental surgeons, nurses, physiotherapists, chiropodists, speech and language therapists, occupational therapists and dietitians who set up:

• in a commune of fewer than 2 000 inhabitants, or in a rural regeneration zone (“zone de revitalisation rurale”);
• for a secondary practice, in an area characterised by an insufficient supply of care.

The duration is set by the local authority, at between two and five years, and the resolution must be passed before 1^st October to apply the following year. The exemption is therefore never automatic: it presupposes that the commune has voted it through. It is claimed in the 1447-C-SD return, together with proof of qualification and of registration with the professional body (“ordre”).

The reflex to have before you set up: check whether the commune you have in mind has passed such a resolution. It is a two-minute question that can be worth several years of exemption — and it is exactly the sort of point that a firm that knows your profession looks at before signing off on an address.

What to bear in mind before choosing your address

• You rent a practice, premises or an office: your CFE is due there, on the rateable value. The domiciliation of your registered office has no tax effect.
• You have no premises at all: the minimum charge is due at the place of your domiciliation. The address then counts, modestly.
• You are a midwife or a garde-malade: check the automatic exemption under paragraph 5 of article 1460 before anything else.
• You are setting up in a sparsely served area: ask whether the commune has passed a resolution under article 1464 D, and claim the exemption in your initial return.
• In every case: the 1447-C-SD return before 31 December of the year of incorporation, and no CFE at all in the first year.

And if the question of your address arises more broadly, it is settled first of all in your articles of association: we have set out the clauses to write into them so that you do not pay twice, and what a change of registered office really costs.

Rules and figures checked against primary sources: articles 1460, 1464 D, 1473, 1647 D and 218 A of the French tax code (the scale in article 1647 D in its version in force on 1^st July 2026), and official guidance BOI-IF-CFE-10-30-10-60, BOI-IF-CFE-10-30-60-10 and BOI-BIC-DECLA-30-40-20-20. Article written by Épiphyse Conseil, chartered accountants specialising in support for the liberal and healthcare professions. Minimum bases are uprated every year and rates are voted locally: check the year and your commune before making any calculation.