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The 2026 finance law: anticipate the effects on wealth strategies

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The finance law is often perceived as an annual budgetary text with limited consequences. In reality, its successive adjustments are gradually changing the balance of wealth strategies.

Business transfer, structuring via holding, tax deferral, management of high incomes: these mechanisms are not disappearing, but their conditions are changing.

The 2026 finance law is in line with this logic. It does not upset the fiscal architecture, but it reinforces the framework for several key mechanisms. These developments call for an upstream analysis, in order to adapt existing structures and to anticipate civil, fiscal and financial impacts.

Business transfer: a Dutreil Pact maintained but refocused

The Dutreil diet is maintained, but its scope is significantly tightened. Les assets not allocated to operational activity are now excluded from the benefit of the partial exemption. In particular, non-professional real estate, primary or secondary residences, rental properties as well as certain heritage assets such as works of art, jewelry, precious metals, vintage vehicles, vintage vehicles, vehicles, boats, pleasure boats, horses or wines are in particular targeted.

For leading holding companies, this evolution requires increased vigilance. The holding of assets within the structure may weaken eligibility for the regime. A prior reorganization may therefore be necessary before any transmission.

In addition, conservation commitments are being extended. The global commitment is extended to eight years and individual commitment at six years.

This reinforcement increases the risk in the event of an early sale or restructuring and requires planning over a longer period of time.

Contribution and transfer: a more demanding tax deferral

The transfer-transfer mechanism provided for in article 150-0 B ter of the CGI is maintained, but reinvestment conditions are tightened. The minimum reinvestment amount is increased to 70% of the sale proceeds, up from 60% previously. The deadline for reinvestment is fixed At three years and titles acquired in use must be kept at Minus five.

The text does not provide for any proportionality mechanism: non-compliance with the 70% quota leads to the complete revocation of the tax deferral. In the event of a donation of the shares received as a contribution, the retention period is also extended by one year to benefit from the purge of the capital gain.

These adjustments do not eliminate the advantages of the system, but they reinforce its economic requirements and the need for a structured reinvestment project.

Taxation of asset holdings: a measure with a strong deterrent effect

The law establishes a specific tax of 20% on the value of certain assets held by asset holding companies. This applies to companies subject to corporate tax, majority owned by a family group, with assets greater than 5 million euros and mainly receiving passive income.

The assets in question correspond in particular to art goods, jewelry, precious metals, precious metals, vintage cars, boats, yachts, horses, as well as residences made available free of charge or rented under abnormal conditions. The tax is calculated on the value of taxable assets and is not deductible from corporate tax.

On the other hand, goods subject to this taxation are excluded from the IFI base. This measure profoundly changes the economic balance of certain purely asset holding structures.

Contribution to high incomes: an assumed sustainability

The differential contribution on high incomes is sustainable as long as the public deficit remains greater than 3% of GDP. Initially presented as temporary, it is now a long-term initiative. It aims to ensure a minimum level of taxation for taxpayers receiving high incomes, especially when they are mostly composed of financial income.

Rental real estate: a new framework for the private lessor

The law introduces a depreciation mechanism applicable to bare rentals, without geographic zoning. Annual amortization can represent between 3% and 5.5% the purchase price excluding land, up to a ceiling of between 8,000 and 12,000 euros per year depending on the nature of the rents charged.

The system involves a nine-year lease commitment, compliance with rent and resource ceilings and, for the former, the completion of work representing more than 30% of the purchase price. In the event of non-compliance with the conditions, amortization may be called into question.

The 2026 finance law does not create a new general wealth tax and does not change the main balances in real estate or inheritance taxation. On the other hand, it significantly strengthens the framework for preferential schemes. The regimes remain accessible, but their implementation requires more rigorous structuring and greater foresight.

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