💼 PLF 2026: New tax on holdings

The finance bill provides for the creation of a new tax on holdings' non-operational assets, that is to say companies which essentially hold financial or real estate assets without any real economic activity.

This 2% tax will apply:

from the end of 2025 for French holdings,

and from the end of 2026 for foreign holdings in which one partner is a tax resident in France.

🎯 Who is concerned?

Are covered companies that:

are subject to corporation tax (IS),

have assets of at least 5 million euros,

derive more than half of their income from investments, rents or dividends,

and are controlled by one or more natural persons.

Clearly, this tax targets 'passive' patrimonial holdings, whose assets are not used for economic activity.

💰 What will the tax be on?

The calculation will be based on the value of real estate, movable and liquid assets not allocated to an activity.

Debts related to the purchase of real estate may, in certain cases, be deducted.

Good news: assets already taxed under this contribution will not be submitted to the IFI in the same year.

🧭 Why this measure?

The government’s objective is to promote productive investments rather than simply holding dormant assets within holdings.

Investment structures such as SIIC, SCR or OPC will remain excluded from the scheme.

🕒 Things to remember

Rate: 2% on non-operational assets

Entry into force: 31 December 2025 (France) / 31 December 2026 (foreign)

Declaration: at the same time as the IS

Not cumulated with the IFI

👉 If you own a wealth holding, it’s time to think ahead: the composition of your assets and the structure of your company could soon directly impact your taxation.