Holding companies in France in 2026: what’s changing for French business owners
A holding company remains a powerful tool for French business owners looking to structure a group, move dividends between companies, finance an acquisition, or prepare for a future transfer of ownership.
But several French tax rules changed in 2026. France’s 2026 Finance Act notably tightened the rules governing contribution-and-sale transactions (apport-cession), narrowed the scope of the Dutreil regime, and introduced a new tax targeting certain asset-holding companies.
Here is what French business owners need to know.
Contribution-and-sale transactions: 70% must now be reinvested, but the deadline has been extended to three years
The French apport-cession regime allows a business owner to contribute shares in an operating company to a holding company they control while deferring taxation of the capital gain arising from that contribution.
When the holding company sells the contributed shares within three years of the contribution, maintaining the tax deferral requires, among other conditions, that part of the sale proceeds be reinvested.
And this is where the rules changed in 2026.
For disposals completed since February 21, 2026 :
the minimum portion of proceeds that must be reinvested has increased from 60% to 70%
the reinvestment period has been extended from two to three years
the types of qualifying reinvestments are more tightly regulated
and the minimum holding period for certain directly reinvested assets or securities has increased from one year to five years
French business owners therefore have more time to reinvest, but they must commit a larger share of the sale proceeds and, in some cases, hold the new investments for significantly longer.
In practice: anyone considering an apport-cession before selling a French business should model the transaction under the new 2026 rules. Timing, available cash, and the type of future investments are now even more important.
A new tax targeting certain French asset-holding companies
Another major change in France in 2026 is the introduction of a tax on certain non-business assets held by predominantly asset-based companies.
However, this should not be misunderstood as a blanket 20% tax on all French holding companies.
Several conditions must be met for the company to fall within the scope of the new rules, including:
the company’s total assets must have a value of at least €5 million;
an individual must directly or indirectly hold at least 50% of the financial or voting rights, or effectively exercise control over the company;
passive income must represent more than 50% of the company’s operating and financial income.
Where these conditions are met, the 20% tax applies to certain assets that are not used for business purposes, including passenger vehicles, yachts, aircraft, jewelry, precious metals, wine and spirits, and certain residential properties made available for the shareholder’s personal use.
The tax applies for the first time to fiscal years ending on or after December 31, 2026.
For most French SMEs using a holding company to own and manage operating subsidiaries, this new tax should not fundamentally alter the structure. It becomes particularly relevant when the holding company has accumulated significant wealth and holds assets that combine business and private use.
Business transfers: the French Dutreil regime becomes more restrictive
Holding companies may also play a role in transferring a French family business, particularly where the holding company qualifies as an active holding company (holding animatrice) and the other conditions of the Dutreil regime are met.
The Dutreil regime still allows, subject to specific requirements, a 75% exemption on the value of transferred shares when calculating French gift or inheritance taxes.
But France’s 2026 Finance Act has tightened the rules.
The individual holding commitment has notably been extended from four to six years.
In addition, certain assets that are not used exclusively for business purposes are now excluded from the value benefiting from the exemption. This may include certain residential properties, passenger vehicles, yachts, jewelry, works of art, wine, and spirits.
French business owners preparing a family transfer therefore need to review more carefully the assets held directly or indirectly through their holding company.
What has not changed in France in 2026
Obviously, not all the rules applicable to holding companies have been overhauled. Here's what remains unchanged this year:
The parent-subsidiary regime
Subject to certain conditions, including ownership of at least 5% of the subsidiary’s share capital and compliance with applicable holding-period rules, France’s parent-subsidiary regime continues to allow dividends to be paid up to the holding company with near-total tax exemption.
As a general rule, a 5% add-back for expenses and charges remains taxable at the holding-company level.
This remains one of the main mechanisms allowing French business owners to reinvest profits within a corporate group instead of immediately distributing them to themselves personally.
French tax consolidation
France’s tax consolidation regime also remains available when the applicable conditions are met, including ownership of at least 95% of the relevant subsidiaries. It allows the group to calculate taxable income on a consolidated basis and, in particular, offset certain profits and losses between group companies.
The reduced corporate income tax rate
A French holding company that meets the SME eligibility requirements may benefit from the reduced corporate income tax rate of 15% on the first €42,500 of taxable profit, with the standard 25% corporate income tax rate applying above that threshold. The former €38,120 threshold, which still appears in many older articles, is therefore no longer the applicable amount.
Should French business owners review their holding-company structure in 2026?
Not necessarily. A holding company that is already being used to own operating subsidiaries and receive dividends does not need to be restructured simply because the calendar has moved to 2026.
However, a review may be particularly relevant if you are preparing:
the sale of your company combined with an apport-cession strategy;
a family business transfer;
an acquisition financed through the holding company;
or if your holding company now owns significant assets combining business and personal wealth.
In these situations, the French tax changes introduced in 2026 may materially affect the structure being considered.
For a broader overview of why French business owners create holding companies, how they work, and their main advantages and limitations, see our blog post “Why and How to Create a Holding Company in France.”
Holding companies in France: plan before you restructure
At Blendy, English-speaking French CPA based in Paris, Montréal and Miami, we help French and international business owners and SMEs structure the accounting, tax, and financial side of their corporate groups.
Whether you are creating a holding company, moving dividends between companies, acquiring another business, considering an apport-cession, or preparing a family business transfer, the right structure depends first and foremost on your company, the cash available, and your long-term objectives.
Considering a holding company or a group restructuring in France? Talk to the Blendy team to model the different options before making a decision.
👉 Contact Blendy to discuss your holding company project, before your competitors decide for you!
With Blendy, English-speaking French CPA based in Paris, Montréal and Miami, take advantage of digital accounting to accelerate your finance process and develop your business.
Pennylane, Dext, QuickBooks and Stripe experts, we support digital and IT service companies, e-Commerce, SaaS, SMBs, in France and internationally.
