Another attack on family holding companies? How long are we going to keep flying blind?

Once again, France is going after the people who build, pass things on and organise.

This time, it is family holding companies that are being put through the grinder. The idea? Taxing undistributed dividends kept in reserve at up to 15 %.

Words spoken without flinching by Charles de Courson, the budget's general rapporteur, as if this were some tax anomaly to be fixed, not the way thousands of company directors prepare their succession, manage their cash, or brace for hard times. In mid-September 2025, he presented his idea to Prime Minister Sébastien Lecornu: a 15 % withholding on the dividends that holding companies receive from their subsidiaries without passing them on, plus an extension of the Dutreil pact from six to eight years. An alternative, he said, to the "Zucman tax", which he considered unworkable.

Taxing money that does not circulate means attacking prudence

In many SMEs and family groups, holding companies play a simple role: structuring, protecting, passing things on.

Building up reserves is not speculation. It is an act of responsible management. It means planning ahead, smoothing things out, reinvesting when it makes sense.

But in this France that is running out of budgetary breath, anything that even remotely looks like a pocket of stability becomes a target.

What does the tax on family holding companies actually cover?

Since this piece was written, the story has moved on, and it deserves to be told precisely. The government tabled its budget bill on 14 October 2025 with a 2 % tax on the non-professional assets held inside "family wealth holding companies". On 31 October, the National Assembly voted it through by 224 votes to 10, but rewritten: amendments from Les Républicains members of parliament took cash out of the tax base and refocused the tax on so-called luxury assets alone.

The final text, enacted in the 2026 budget law and validated by France's Constitutional Council on 19 February 2026, sets a rate of 20 % on the market value of non-professional assets: yachts, aircraft, luxury cars, jewellery, precious metals, racehorses, wines and spirits, homes the director keeps for personal use. The tax only targets companies controlled by more than 50 % by a family circle, where more than half of the income is passive, and whose assets exceed 5 million euros. Cash and business assets are excluded. Codified in article 235 ter C of the French general tax code, it applies to financial years ending on or after 31 December 2026, for expected revenue of around 100 million euros.

In other words, the raw version I was denouncing here was largely defused along the way. So much the better. But remember the mechanism: a tax tabled at 2 % on a broad base, voted at 20 % on a narrow base within a fortnight, rewritten several times before being enacted. That is not the solidity you expect from a tax rule. It is exactly the improvisation I was describing.

This is not a policy, it is permanent improvisation

You cannot tell company directors to take risks and then blame them for planning ahead.

You cannot heap praise on the entrepreneur and then act surprised that they structure their assets so those assets survive political mood swings.

This kind of announcement, even while it is "under discussion", is enough to break confidence. Because everyone understands that if the idea is put on the table once, it can come back tomorrow in another form. The path this tax has taken proves it: what was narrowed this year can be widened again next year.

The message is simple: anything that endures will be taxed

After the "Zucman tax", that 2 % floor levy on wealth above 100 million euros which the National Assembly rejected, the same reflex is being recycled: hit wherever the pushback is weakest. Holding companies, Dutreil pacts, cash waiting to be reinvested.

But by constantly labelling structures as "dubious optimisation", you end up sending a dangerous message: anything that is stable, long-term or well-prepared becomes suspect.

Is a company reserve really dubious optimisation?

Let us say it again, calmly: a reserve is not fraud.

It is a way of protecting companies. Of preserving their ability to fund themselves without taking on debt. Of withstanding volatility.

Real responsibility would be to build a stable, legible, lasting framework. Not to invent a new tax every three months depending on the holes in the budget.

Because by keeping firing at the shock absorbers, it is the whole engine that risks giving out.

What could put the long term back into tax policy?

Rather than piling up tax reactions the way you bail out a leak with a bucket, I propose a fundamental overhaul:

• A 5-year moratorium on any tax affecting business succession and reserves. Let the players invest and pass things on without the rules changing every six months.
• A multi-year commitment framework between the state and entrepreneurs, in which the tax rules of the game are clarified, documented and non-retroactive. As in the countries that inspire confidence.
• A public fiscal-stability indicator, published every year, measuring in concrete terms the number of reforms, laws and decrees, and their effect on companies. So that we finally grasp the harm we are doing.

Because you do not rebuild France with patches. You rebuild it with people who still believe in it enough to invest in it.

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Sources

• FranceTransactions.com, The taxation of family wealth holding companies in the sights of the 2026 budget law (in French): Charles de Courson's proposal for a 15 % withholding on undistributed dividends.
• Bulletin des Communes, Charles de Courson proposes targeting family holding companies rather than the Zucman tax (in French): 15 % withholding, Dutreil pact extended from six to eight years, alternative to the Zucman tax.
• Le Club des Juristes, Budget 2026: the National Assembly adopts the tax on family wealth holding companies (in French): vote of 31 October 2025, 224 votes to 10.
• Scala Patrimoine, The new tax on family wealth holding companies: what the 2026 budget law changes (in French): 20 % rate, 5 million euro threshold, article 235 ter C of the general tax code, validation by the Constitutional Council on 19 February 2026, expected revenue of around 100 million euros.
• Baker Tilly, Everything you need to know about the new tax on family wealth holding companies (in French): tax base refocused on luxury assets, exclusion of cash and business assets, financial years ending on or after 31 December 2026.
• Touteleurope.eu, Budget 2026: the National Assembly rejects the Zucman tax (in French): rejection of the Zucman tax by the National Assembly.