1. The VAT liability ratio (90%)
Payroll tax is due where receipts carrying a right to deduct VAT represent less than 90% of total receipts for the preceding year (and not of "taxable turnover" in the accounting sense). The liability ratio that determines the base of the payroll tax is the ratio between the receipts and other income that did not carry a right to deduct VAT (numerator) and total receipts and other income (denominator), in accordance with article 231, 1 of the French Tax Code. If that ratio stands at 70%, the tax is charged on 70% of the remuneration paid. The 10% threshold is not a tolerance but a statutory threshold: full exemption corresponds to a liability ratio not exceeding 10%, that is, to being subject to VAT on at least 90% of turnover. The tax authorities do, however, allow the base to be tapered for ratios between 10% and 20% (11%: 2% of remuneration; 12%: 4%; and so on up to 20%: 20%), so as to avoid a cliff effect (BOFiP BOI-TPS-TS-20-30, § 220). It is essential to distinguish operations outside the scope of VAT (which carry no right to deduct) from operations exempt within the scope (which are in principle treated as operations carrying no right to deduct, subject to a limited list of exceptions).