2026 Finance Bill - New Tax on Family Holding Companies

Article 3 of the 2026 Finance Bill introduces a major measure: the creation of a 2% tax on the financial assets of family holding companies.

The tax would apply to:

• Holding companies subject to corporate income tax (CIT), or foreign entities subject to an equivalent tax
• Whose total asset value reaches at least €5M
• Where more than 50% of income comes from passive income (i.e.: dividends, interest, rents, etc.)
• Controlled by one or more individuals holding at least 33.33% of the rights.

Important: these criteria are cumulative and, for the sake of “fairness”, the tax would also apply to French tax residents holding foreign-based holdings.

Tax base and rate:

• Rate: 2% of the market value of assets not allocated to an operational activity
• Annual application
• First deadline: fiscal years ending 12/31/25 (12/31/26 for foreign holdings)

Impacts and legal issues:

This measure – major from a wealth planning perspective – could significantly alter the attractiveness of wealth holding structures, encourage reallocation toward operational assets or assets excluded from the scope of this provision, or require a comprehensive review of structuring and succession strategies.

Absent parliamentary agreement and government censure, the original text will prevail.