French enterprise zones and tax relief: what an address will never give you

What is still open, and what is closed

Let us start with the map of the schemes, because many articles online still present as available regimes that no longer are.

In other words, if you are setting up your business today, the zone franche urbaine no longer concerns you. The scheme that matters is that of the France Ruralités Revitalisation zones, created under the France Ruralités plan, which replaced the zones de revitalisation rurale on 1 July 2024.

What an FRR zone location actually gives you

Article 44 quindecies A of the code général des impôts (the French general tax code, « CGI ») provides an exemption from income tax or corporation tax for activities created or taken over in a zone, until the end of the fifty-ninth month following the start of the activity — that is, close to five full years.

The exit is tapered: profits become taxable again at 25 %, then 50 %, then 75 % over the three twelve-month periods that follow. The benefit therefore in fact spreads over eight years.

A decisive point for the liberal professions: they are eligible. The provision covers activities that are « industrielles, commerciales ou artisanales, au sens de l'article 34, ou professionnelles, au sens du 1 de l'article 92 » — industrial, commercial or craft activities within the meaning of article 34, or professional activities within the meaning of article 92(1), this last category being precisely that of the bénéfices non commerciaux (BNC, non-commercial professional profits).

Two conditions frame the scheme: the business must employ fewer than eleven members of staff, and the whole of its activity and its operating resources must be located within the zone.

A relaxation introduced in February 2026

That last condition — exclusive location within the zone — was the main point of friction. The Finance Act for 2026 relaxed it for sedentary activities: a business may now generate up to 25 % of its turnover outside the zone without losing the benefit of the regime, the corresponding profits being taxed on a pro rata basis.

The point that brings down most arrangements

Here is what we have to write, even though it runs against the immediate interest of a domiciliation company: placing your registered office in an enterprise zone gives you no right whatsoever to an exemption.

The published tax doctrine is unambiguous. Locating operating resources in the zone is a condition that is « nécessaire mais non suffisante » — necessary but not sufficient: the taxpayer must carry on a genuine activity there, « concrétisée par une présence significative sur les lieux et par la réalisation d'actes en rapport avec cette activité », that is, evidenced by a significant presence on site and by carrying out acts connected with that activity — receiving clients, delivering the services, receiving and dispatching goods.

An administrative address, with no practitioner, no patient seen and no equipment, satisfies none of these. If someone sells you a domiciliation in an enterprise zone as a way of obtaining an exemption, that is not tax advice: it is an exposure to reassessment that you alone will carry.

So what is your address for, in this landscape?

Three things, and it is better to name them honestly.

• Nothing at all, as regards zone-based exemptions on profits. Those follow the place where the activity is actually carried on, not the registered office set out in the articles.
• Determining your CFE (cotisation foncière des entreprises, the local business rates), but only if you have no premises. That is the case of the visiting nurse or the locum: we set it out in detail in our article on CFE and domiciliation.
• Keeping your registered office stable while your activity itself moves around. That is the legitimate use of domiciliation: your administrative address no longer changes, and your working premises can evolve without a formality to transfer the registered office.

What to check before setting up

• The classification of the commune. FRR zones are defined by ministerial order (« arrêté »); classification depends on population, density and median income. A neighbouring commune may be classified when yours is not.
• The date of creation. The exemption covers businesses created or taken over during the eligibility period, up to 31 December 2029.
• Headcount. The threshold of eleven members of staff is assessed each year: rapid growth can cost you the regime.
• Local exemptions. Zone-based schemes often come with exemptions from CFE or from property tax, but these most often depend on a decision of the commune's council: they are never automatic.

A plan to set up therefore has to be looked at commune by commune, and not solely from the angle of the address. This is exactly the kind of trade-off that the firm behind Domisiège examines before validating a choice.

Sources checked: articles 44 octies A and 44 quindecies A of the code général des impôts in the version in force in August 2026, the latter as amended by law no. 2026-103 of 19 February 2026, the Finance Act for 2026; published tax doctrine BOI-BIC-CHAMP-80-10-20-20 and BOI-BIC-CHAMP-80-10-75. Article written by Épiphyse Conseil, a chartered accountancy firm specialising in advising the liberal and healthcare professions. Zone boundaries are set by ministerial order and revised periodically: check the classification of your commune before taking any decision to set up.