The French government has made major changes to its tax laws regarding income from shares and capital gains, primarily through **article 163 bis H** of the General Tax Code (CGI), introduced by **article 93** of the 2025 Finance Act. This new rule focuses on the gains made by employees or managers from various types of shares, such as common shares, preferred shares, stock options, and free shares, which they receive as part of their job. The previous approach was reversed: now, gains are considered part of wages by default, with only a limited portion qualifying for the capital gains tax treatment. The cap for this capital gains portion is calculated using the formula: 3 × acquisition price × financial performance − acquisition price, where financial performance is the ratio of the company's value at the time of sale to its value at the time of purchase. For the capital gains portion to qualify, three conditions must be met: the shares must have been held for at least two years, they must carry a risk of capital loss, and the gain must be received in exchange for performing a job. The portion of the gain that meets these criteria is taxed at a flat rate of 31.40% in 2026, after an increase in the CSG (a social contribution on capital income). The remainder of the gain is treated as wages, exempt from most social contributions but subject to a 10% "liberating salary" contribution, as outlined in **article L137-42** of the Social Security Code. If the conditions are not met, the entire gain is subject to social contributions. The 10% contribution, which was initially set to apply only until December 31, 2027, has been extended by the 2026 Social Security Financing Act to align the social and tax regimes. The 2026 Finance Act introduced several retroactive corrections, effective from February 15, 2025, to simplify the application of the new rules. The value of shares used for calculations is now based on their value at the time of acquisition or subscription, rather than the price paid, which benefits shares from stock options and BSPCE (Share-Based Profit-Sharing Contracts) where the exercise price was fixed at the time of allocation. Debts associated with these shares are adjusted to reflect repayments, ensuring accurate calculations. Additionally, the cap is reduced by the amount of dividends and capital repayments received during the holding period, as these have already been distributed and should not be counted twice. The 2026 Finance Act also relaxed the rules for BSPCE. **Article 163 bis G** of the CGI now limits subscription warrants to certain companies in France, including those that are not listed, have a capitalization under 150 million euros, and have been registered for less than fifteen years. The threshold for capital ownership by individuals or legal entities has been lowered from 25% to 15%, allowing more companies that have gone through multiple funding rounds to qualify. The scope of this provision has also been extended to employees of subsidiaries, with the requirement that the intermediate subsidiary must be directly owned by the company at least 75%.