The 2026 budget bill was definitively adopted by the National Assembly on February 2, 2026, in its new version resulting from the application of Article 49.3.

What are the main tax measures affecting taxpayers?

✔️ The differential tax on the highest incomes (CDHR) has been extended: households with an annual income exceeding 250 K€ for a single person (500 K€ for a couple) are taxed at a minimum average rate of 20%.

✔️ Introduction of a new “Holding” tax on financial assets:

➨ 20% rate
➨ Threshold for application: at least €5 million in assets
➨ Tax base: non-business assets held by a holding company (excluding assets related to business operations and cash).
➨ Works of art, collectibles, and antiques are excluded

✔️ The exceptional tax on the profits of large companies (CEBGE) is extended for companies with revenue of at least 1.5 billion euros.

✔️ The Dutreil Pact is subject to stricter regulations:

➨The scope of eligible assets has been narrowed: luxury items (works of art, cars, and especially housing) that are not used exclusively for business purposes are excluded from the tax relief.
➨These assets may still qualify for the Dutreil exemption if they are used exclusively for the company’s business for at least 3 years prior to the transfer and until the end of the holding period
➨The individual holding period for company securities has been extended from 4 to 6 years.

✔️ The “contribution-transfer” mechanism has been tightened:

➨The holding company must reinvest at least 70% of the proceeds from the sale (previously 60%)
➨The mandatory reinvestment period has been extended from 2 to 3 years
➨The acquired assets must be held for at least 5 years (compared to 1 year)
➨ and, most importantly, real estate activities as defined in Section L of the NAF classification—including real estate brokers, developers, and land subdivers, as well as real estate management and operation activities—are now excluded

Applicable to all transfers effective as of the publication of the 2026 Finance Act.

But all is not lost: the Prime Minister has referred the matter to the Constitutional Council for review of the following articles:
➨ Article 7, which taxes the non-business assets of holding companies
➨ Article 8, which excludes certain assets from the Dutreil-DMTG exemption (Article 787 B of the General Tax Code),
➨ Article 11, which tightens the conditions for qualifying for the carryover provided for in Article Article 150-0 B ter of the General Tax Code.

“I hope that they will not take effect until the Constitutional Council has verified that the rules they establish are in accordance with the Constitution.”

Let’s hope that the Constitutional Council will be able to restore a certain balance and fairness to this organic law so that it does not have too severe an impact on the economy and the survival of French businesses.

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