The Minister of Economy, Roland Lescure, recently told the Association of Economic and Financial Journalists (Ajef) that a specific rule in the upcoming budget will be revised. This rule concerns a tax benefit that allows entrepreneurs to transfer their company shares to a holding company they control, rather than selling them directly. If the shares are sold, any capital gain — the profit from the sale — may not be taxed immediately. This deferral continues if the holding company reinvests the money into economic activities. However, if the owner transfers the shares to their children or if they pass away, it's common for the capital gain to never be taxed at all.
The draft finance bill (PLF) presented last Thursday explains that this scheme has become increasingly popular, leading to a doubling of capital gains placed on tax deferral between 2021 and 2023, reaching 34 billion euros. The note adds that these amounts are "essentially concentrated among the 0.01% richest people." The bill now proposes that these capital gains be subject to immediate income tax if they are passed on through donations or inheritance.
Lescure said it will be necessary to "clean up" this provision, explaining that the goal is to "avoid abuses" and "not endanger the transfer of businesses." He emphasized the need to "ensure, within the framework of an organized transfer, an inheritance, that the heirs are not forced to sell the company to pay their taxes."
The Meti (movement of intermediate enterprises) expressed concern that this provision could dramatically increase the cost of transferring family businesses in France and, in practice, block them, forcing businesses to be sold during succession. They hoped the provision in the PLF resulted from a drafting error, as its consequences for the French productive fabric would be "vertiginous."
According to the firm EY, such a reform could profoundly change the costs and strategies of asset transmission that have been in place for several years by many entrepreneurs, family shareholders, and family groups. A survey by Bpifrance, published at the end of 2025, which questioned more than 5,000 managers, 310,000 SMEs, 58,000 medium-sized companies, and 1,200 large companies, indicated that 370,000 potential transfers could occur in the next five years (including 2026), three times more than the volumes observed so far. If these transfers were maintained, they would lead to 130,000 transfers.
French Minister to Review Tax Provision on Business Transfers Amid Concerns Over Impact on SMEs
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