In Depth | Management Packages: publication of administrative comments on the new tax regime for management package gains
The French Finance Act for 2025 introduced a new tax regime for management packages, codified in article 163 bis H of the CGI, and the related administrative comments were published in the BOFiP on July 23rd, 2025.
Although they are subject to public consultation until October 22nd 2025, and are therefore not definitive, these comments provide a number of welcome clarifications on the assessment made by the tax authorities concerning :
— the securities covered by the regime
— the notion of consideration for the functions of director/employee
— the determination of the share subject to the capital gains regime in the presence of securities of a different nature
— the impact of price supplements
— the impact of share exchange transactions
Find below the complete analysis signed by our tax team.
