French Budget 2026 – Overview of Significant Provisions
/The French Finance Act for 2026 introduced several measures affecting private wealth structuring and investment strategies. Some provisions were expected and were discussed in previous legislative debates. Others target specific structuring techniques traditionally used for wealth preservation or intergenerational planning. Philippe Stebler, of Stebler Moati Avocats, Paris, explains the tax provisions that were adopted, including (i) the extension of minimum income taxation of 20% for individuals, (ii) adjustments to the tax deferral regime applicable to share-for-share exchanges occurring before cash-outs through holding companies, (iii) the imposition of a new 20% tax is imposed on certain luxury assets held through holding companies, (iv) the exclusion of luxury assets held by companies from the “Dutreil” regime, a major tax relief mechanism for business transfers by gift or inheritance, and (v) an extension of the temporary surtax for large corporations.
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