Wealth Management Holdings: The 20% Tax on "Dormant" Assets

This is one of the most controversial measures in the 2026 budget bill. The government is imposing a 20% tax on certain assets held by family holding companies when those assets are not used for operational purposes.
 

A Strictly Defined Scope of Application
The tax will apply to companies subject to corporate income tax—whether French or foreign—provided that several conditions are met. The market value of the assets must be at least 5 million euros, the company must be controlled by an individual, and more than 50 percent of its revenue must qualify as passive income.
 

The text precisely defines the concept of control, taking into account direct and indirect ownership, including that held by family members. The objective is clear: to target holding companies whose primary activity is asset ownership.
 

A tax base focused on recreational assets
The tax base targets assets that are emblematic of wealth accumulation: non-business vehicles, boats, airplanes, helicopters, residences made available to shareholders, jewelry, precious metals, horses, wines and spirits, and property related to hunting and fishing.
 

Works of art, antiques, and collectibles are explicitly excluded, reflecting the legislature’s intent to limit the tax to certain specific uses of cultural heritage.
 

A New Arrangement with the IFI
When the company is incorporated in France, the tax will be payable by the company itself. For foreign holding companies, the tax will be borne by shareholders who are French tax residents, subject to an overall cap of 75 percent of income.
 

Key point: Securities issued by companies subject to this tax would be exempt from the IFI. This represents a new interplay between corporate taxation and wealth taxation, which could, however, raise constitutional issues.