France’s draft Finance Bill 2019, currently before Parliament, proposes a new anti-abuse provision for corporate income tax, disregarding transactions that are purely motivated by a tax benefit that is against the purpose of the underlying rules, or imposing penalties of up to 80 percent of the tax avoided.  

Also, tax deduction of a company's net interest expenses will be capped at the higher of EUR3 million or 30 percent of adjusted earnings before interest, taxes, depreciation and amortization.