France’s National Assembly voted 11 to 10 on October 30 to attach a new levy to the country’s budget: 0.055 euros for every gigabyte of data delivered to a user in France, billed to the companies that send it, and timed to take effect with the 2027 budget. If the Senate lets the amendment stand, the unit of French tax policy stops being revenue, profit or payroll and becomes the byte.
The mechanism is what makes the proposal new. France already taxes the local turnover of large digital companies at 3%, a levy built on the assumption that profit can be located somewhere. A charge per gigabyte attaches to reception instead, which is how it reaches Google, Netflix and Meta without an argument about where their French business is booked. A two-hour film in high definition runs to a few gigabytes. At the stated rate, a terabyte of monthly traffic carries 55 euros before any pass-through, and a household with a television, a games console and two teenagers will generate several.
The amendment’s sponsors describe the levy as making platforms pay for the capacity they consume. That argument has a history. European telecom operators have spent years asking Brussels to make the largest content companies contribute to network costs, a proposal usually called fair share, and the European Commission has repeatedly declined to turn it into legislation. The published terms of the French text do not say where the revenue goes. What they do is put a number on an argument the telecom industry has been making without one.
Metering has a poor record as a commercial model. Fixed and mobile operators charged by the minute and by the text message until flat-rate plans made the meter pointless, and the plans won because customers preferred a predictable bill to a cheap one. The comparison only goes so far. Bytes are not scarce inside the network; capacity is, and capacity is expensive exactly where the network meets the customer, which is why the operators have an argument even if they have not won it.
A tax on gigabytes has to be assessed somewhere, and the somewhere is contested. Modern distribution places caches inside the operator’s own network, so the byte a collector can count at the interconnection point may be a cache fill rather than a viewer’s stream. Encrypted traffic cannot be sorted by type, which means a byte of short video and a byte of payroll data carry the same rate. Routing, delivery contracts and the location of the counting equipment will determine the bill as much as consumption does.
Every digital levy in Europe so far has been a percentage of something, because percentages are what tax administrations know how to audit: 2% of local revenue in Britain, 3% in France, Spain and Italy. Each of those taxes was designed to survive the objection that profit is booked in Dublin, and each drew the same counter-objection from Washington, which has opened trade investigations into digital taxes before and treated them as discrimination against American companies. A per-gigabyte charge does not solve that problem so much as move it. The incidence is even more plainly foreign, since the companies most exposed are the ones whose content crosses a border by definition.
The European layer is the harder constraint. A member state can tax consumption, a principle the union accepts. It cannot require that data be stored or routed a particular way to make the tax collectable, because the rules on the free flow of data prohibit exactly that. Nor does the amendment say who collects the levy, at what threshold, or how traffic between subsidiaries of one group is treated. A tax that needs a meter also needs an administration, and the text describes a rate without describing the machinery.
The politics are thin. One vote in a chamber that will not be the last to speak, in a budget cycle that has already produced more amendments than sitting hours. The Senate, where the centre-right holds a majority and has spent a decade trimming levies on capital, is the next room. Its members have rewritten budget amendments of this kind before, and a tax whose cost falls mainly on American platforms is easier to oppose upstairs than downstairs.
Whoever pays the levy at the point of collection will try to pass it on. French broadband and mobile bills are among the cheapest in western Europe, a fact that regulators cite and ministers repeat, and a per-gigabyte charge on streaming is the sort of cost that ends up on a subscriber’s invoice because there is nowhere else for it to go. That is the political risk the sponsors have taken on: a tax on platforms that arrives as a line item on a household bill.
There is a larger question underneath, and it is not about France. A byte is a quantity that exists only in transit. Income tax measures what is earned, value-added tax measures a transaction between two parties, and utility regulation meters what is produced and delivered, because the resource is scarce at the point of production. Bandwidth is scarce at the point of delivery, and its price has fallen for thirty years faster than any index a finance ministry can construct. A rate fixed at 0.055 euros becomes stricter every year that transmission gets cheaper, which may be the design the authors wanted and is certainly the reason the industry will describe it as a tax that rises without a vote.
The defenders of the amendment have found something that cannot be relocated to Dublin. They have not yet shown that it can be counted, or that a revenue authority can tell a gigabyte that carries a film from one that carries a diagnosis. Those are questions for the Senate, and then for a court.
