PROPOSED TAX BILL ON HOLDING COMPANIES OWNED BY FRENCH RESIDENTS
As part of the French finance law for 2026, Article 3 introduces a new tax measure targeting holding companies—whether French or foreign—owned by individuals who are tax residents of France.
This reform, still under parliamentary discussion, could significantly affect your wealth situation if you are planning to move to France or already reside there.
A holding company would be subject to this tax if it meets all of the following cumulative criteria:
- Companies headquartered in France or abroad, subject to corporate income tax
- Holding financial or real estate assets with a market value ≥ €5 million
- Earning passive income (dividends, interest, rent, capital gains) representing more than 50% of total revenues
- Controlled by an individual or a family group holding at least 33.3% of financial or voting rights
- No operational activity involving the production of goods or services
- The tax base corresponds to the net value of non-professional assets
The proposed tax rate is 2% per annum.
This 2% tax would apply from 2026 for companies headquartered in France, and from 2027 for those headquartered abroad.
