2026 Finance Bill: Key Takeaways from the Amendments Adopted by the French Parliament
The parliamentary debate on the 2026 Finance Bill, focused on state revenues and underway since October 24, was suspended this Monday at midnight.
Marked by particularly intense and extensive discussions, this first review concludes with nearly 2,000 amendments still pending examination. Parliamentarians will resume work on the 2026 Finance Bill after the vote on the first part of the Social Security Financing Bill, currently scheduled for November 12.
Pending the adjustments that will take place during the parliamentary shuttle between the National Assembly and the Senate, the text has already undergone several significant modifications through the adoption of amendments in the areas of:
Wealth Taxation
- Extension of the differential contribution on high incomes (CDHR) until the year in which the French public deficit falls below the 3% threshold (amendment I-3358).
- Introduction of a tax on holding companies: Article 3 of the draft Finance Bill establishes a 2% tax on non-professional assets held by holding companies, when an individual owns at least one-third of the rights.
However, amendment I-3052 and sub-amendment I-3901 restrict the scope of the tax: it would only apply to so-called luxury assets (yachts, racehorses, or aircraft, etc.).In addition, lawmakers introduced two changes:
1. The tax rate would be increased to 20%;
2. The threshold of individual ownership in the capital of a holding company would be raised from 33% to 50%. -
Replacement of the IFI with a tax on unproductive wealth (amendment I-3379): the IFI base would be expanded to include unproductive assets (tangible personal property, digital assets, life insurance for funds not allocated to productive investment). The progressive scale would be replaced by a flat rate of 1% applied to the portion of wealth exceeding €1.3 million (sub-amendment I-3910).
Corporate Tax
- Extension in 2026 of the exceptional contribution on large company profits (amendment I-3838): the rate is reduced to 5% for mid-sized companies and increased to 35.3% for large enterprises.
- Taxation of multinationals on the share of global profits generated in France (amendment I-1938): any company conducting business in France is taxed proportionally to the ratio of its revenue generated in France to its global revenue, including subsidiaries owned more than 50%.
- Introduction of a contribution on exceptional dividends for companies with revenue exceeding €750 million, at a rate set between 20% and 33% (amendment I-2392).
- Reform of the contribution-in-kind deferral regime (amendment I-3521): the reinvestment commitment amount is raised to 80% over a 5-year period, and any non-reinvested portion becomes taxable. The deferral is also transferred to heirs in the event of death.
- Expansion of the corporate tax reduced rate base of 15% for SMEs (amendment I-2531): the threshold is now raised to €100,000.
- Tax on share buybacks by large companies (amendment I-105): the applicability threshold is lowered to €750 million in revenue, and the tax now applies to the acquisition value of the shares. The rate is increased to 33%.
International Taxation
- Restoration of the previous exit tax regime (amendment I-807): the period will again be extended to 15 years.
