Major changes in the 2025 finance bill in France: Impact on the assets and taxation of individuals and businesses

Here is a summary of the main reforms voted on and their implications:

1. Revaluation of the progressive scale of income tax

The law indexes the income tax scale to inflation (+1.8 %), in order to neutralize its effects on the level of household taxation.

Progressive scale of personal income tax 2025 on 2024 income:

•  Taxation of High Incomes

Individuals with a reference tax income of more than €250,000 for a single person and €500,000 per year for a couple and whose income tax rate is less than 20 % will be called upon to contribute to the recovery of public accounts. These measures aim to ensure fair participation of the highest incomes in the national budgetary effort.

• Taxation of real estate capital gains in LMNP

The taxation of furnished accommodation rentals is modified. Depreciation deducted during the rental period of a property will now be taken into account when it is sold and therefore reintegrated into the calculation of the capital gain. This modification results in an increase in the taxable base upon resale, directly impacting the taxation of LMNP investors. However, certain accommodations such as those located in certain service residences will not be affected by the removal of this tax niche.

Numerical example:

• Acquisition of the property: €300,000
• Cumulative depreciation over 10 years: €100,000
• Selling price: €400,000

Before the reform:

• Taxable capital gain: €400,000 (sale price) – €300,000 (purchase price) = €100,000

After the reform:

• Adjusted purchase price: €300,000 – €100,000 (depreciation) = €200,000
• Taxable capital gain: €400,000 – €200,000 = €200,000

• Notary fees

The government has allowed departments to increase transfer taxes for consideration (DMTO), often referred to as "notary fees", by 0.5 %. This initiative, in effect from 1 April 2025 to 31 March 2028, aims to offset the budgetary constraints imposed on local authorities. In practice, for an old property, the DMTO rate could thus increase from 4.5 % to 5 % of the transaction amount. For example, the purchase of a property for €400,000 could result in additional costs. However, an exemption is provided for first-time buyers, so as not to penalise households accessing property for the first time. This increase, although optional, should be adopted by many departments facing increased budgetary constraints.

• Exceptional Contribution on Large Companies

An exceptional and temporary contribution will be put in place on the profits of large companies for the financial year ending on or after December 31, 2025. This contribution will concern companies whose turnover in France is greater than or equal to 1 billion euros and which are liable for corporate tax. The corporate tax rate would increase to 30.15% (instead of 25%) for companies with a turnover of less than 3 billion and a rate of 35.3% (instead of 25%) for companies with a turnover of more than 3 billion.

• Extension of the reduction for retiring managers

The government has extended until December 31, 2031 the tax system that grants retiring executives a €500,000 tax deduction on the capital gain generated by the sale of their shares (Article 150-0 D ter of the CGI). Initially valid for sales and buybacks made until December 31, 2024, this extension aims to simplify the transfer of businesses by offering an attractive tax framework to executives wishing to sell their company as they approach retirement. To benefit from this tax deduction, several criteria must be met, including the transfer of all the shares, stocks or rights held by the transferor in the company concerned. In addition, the measure also includes price supplements associated with these transactions, provided that they are received between January 1, 2025 and December 31, 2031. By extending this tax advantage, the government aims to encourage the renewal of the entrepreneurial fabric while avoiding excessive taxation that could hinder business transfers and penalize managers when they leave.

7. Management Packages

The tax framework for management packages has been clarified to better regulate these incentive compensation schemes intended for senior executives. A management package brings together various financial mechanisms (free shares, stock options, BSPCE, buybacks, convertible bonds, etc.) allowing executives and managers to make a capital gain in the event of a resale of the company.

The gains from the sale of securities acquired via a management package are now divided into two parts:

Part taxed as a capital gain This portion of the gain is subject to the single flat-rate deduction (PFU) of 12.8 %, to which are added social security contributions of 17.2 %, bringing the total tax to 30 %. Taxpayers can, however, choose the progressive scale of income tax if this is more advantageous for them.

Part taxed as wage income This fraction is subject to the progressive income tax scale, with a marginal bracket of up to 45 %, increased by the exceptional contribution on high incomes of 3 % or 4 %. In addition, a specific wage social contribution of 10 % is applied, bringing the total taxation of this part between 55 % and 59 %.

Article n°2 / Millennium invest