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France's new evergreening tax targets pharmaceutical companies that allegedly delay generic drug market entry through secondary patents, but the law's scope and enforcement mechanisms remain unclear. With no administrative guidance issued since the tax took effect on December 31, 2025, companies face uncertainty about compliance requirements, assessment procedures, and the criteria for determining unjustified commercial exclusivity.

French tax courts have issued various decisions that may have a significant impact on the application of the French CFC rules.