In April 2026, the General Directorate of Public Finances (DGFiP) published Statistical Bulletin No. 45, providing a comprehensive assessment of the wealth tax (IFI) for the year 2025. The figures confirm an 8% increase in tax revenues from this tax, totaling €2.3 billion. However, it is primarily one figure that has sparked debate: 13,300 households subject to the IFI would not pay income tax. Since then, the topic has become prominent in parliamentary and media discussions, raising numerous questions about the structure and fairness of the French tax system.

This article proposed by PRAX Avocats, a firm specializing in business law and legal advice for companies, deciphers what these data truly mean and draws useful lessons for leaders, investors, and entrepreneurs.

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A Changing Tax Context

Rising Revenues Despite a Stable Base

In 2025, 193,600 households were liable for the IFI. This figure is relatively stable, but the total amount of tax collected has increased. This 8% growth can be explained by the continuous revaluation of the real estate market, particularly in large urban areas, and by the reduction of deduction capacities.

In other words, the increase does not stem from an expansion of the taxpayer base, but rather from a mechanical increase in property values, observed across the entire territory.

For entrepreneurs holding professional real estate or for investors who have structured their assets through real estate investment companies (SCI), this trend calls for particular vigilance regarding asset structuring and reporting obligations.

The Debate on "Non-Taxable Taxpayers"

The figure of 13,300 IFI households without income tax has fueled a quick interpretation: that of "rich but non-taxed" taxpayers. In reality, the statistic tells a different story.

According to the DGFiP, these households have a median taxable income of €38,900 and an average net real estate wealth of €2.4 million. They therefore have more wealth than income. Half of them are over 68 years old, often retired, long-time owners of a property whose value has significantly increased but which generates little or no income.

This profile perfectly illustrates one of the structural paradoxes of the French tax system: wealth is taxed independently of income. Thus, a modest income asset can be subject to the IFI simply because its real estate has appreciated over the decades.

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The Economic and Legal Stakes of This Evolution

For Wealthy Individuals: Increased Tax Pressure

Maintaining a tax based solely on real estate wealth, without regard to actual contributory capacity, can lead to cash flow tension situations.

Some elderly or retired individuals may sometimes have to sell part of their wealth to pay the IFI due to insufficient liquidity. The DGFiP acknowledges this specificity, but the system remains unchanged for now.

For entrepreneurs and leaders, the issue is of a different nature: that of the boundary between private and professional wealth. The tax treatment of assets allocated to professional activity (premises, commercial buildings, real estate holdings, etc.) must be anticipated to avoid partial or total liability to the IFI.

For Investors and Business Leaders: Vigilance on Holding Structures

Many start-ups and SMEs organize their wealth through holding companies (SCI, family LLCs, wealth management holdings).

In these configurations, the qualification of real estate assets, the nature of participations, and the actual use of properties determine the taxable base for the IFI. Founders and leaders must therefore rely on specialized corporate legal advice in taxation to avoid misinterpretation of the text or reassessment.

Business law and tax law intersect here: an acquisition operation, a restructuring, or the transfer of a participation can significantly alter the IFI base.

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How to Anticipate and Optimize Your Situation

1. Precisely Identify Your Taxable Wealth

The first step is to distinguish, within the real estate wealth, what is taxable and what is not.

Excluded from the calculation are:

Professional assets used in the entrepreneur's main activity;
Assets held through operational companies where the manager actually performs a management function;
Certain rental investments under conditions (notably in dismemberment or bare ownership).

A business lawyer or tax advisor can provide a detailed interpretation of the texts and administrative comments to correctly qualify each element of the wealth.

2. Use Legal Levers for Reduction and Adjustment

The IFI allows for certain reduction levers, under strict conditions:

Debt deductions (ongoing real estate loans);

Reductions for donations to recognized public utility organizations (up to 75% of the donated amount, within certain limits);

Capping the IFI based on income, aimed at avoiding excessive tax pressure.

In practice, these levers require a comprehensive analysis of the wealth and tax situation of the household. Each situation is unique, hence the relevance of tailored support.

3. Effectively Structure Professional and Personal Wealth

For entrepreneurs and start-ups whose personal wealth sometimes overlaps with professional wealth, structuring remains essential.

A clear organization between operating company and real estate holding company, a balanced use of property dismemberment, or anticipating succession can help optimize taxation while protecting the business.

At PRAX Avocats, our teams assist leaders in designing coherent wealth and legal strategies: choosing the appropriate structure, drafting shareholder agreements, balancing yield and legal security.

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Towards a More Nuanced Debate on Wealth Taxation

The publication of the IFI 2025 statistics brings the tax issue back to the forefront of public debate, but the data show that the reality is more subtle than media discourses suggest.

This is not about tax evasion or aggressive optimization, but rather the mechanical effect of a tax disconnected from the actual incomes of taxpayers.

For economic actors, entrepreneurs, or investors, the priority remains to anticipate and properly structure their assets to avoid the undesirable effects of an evolving tax system.

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Contact the Firm

Each wealth situation being unique, it is advisable to obtain personalized legal advice before any decision. PRAX Avocats, specialist in business law, intellectual property, labor law, and support for start-ups, assists leaders and investors in all their tax and wealth issues.

For personalized legal support for your business project or wealth structuring, contact PRAX Avocats.

Real Estate Wealth Tax (IFI) 2025: a controlled increase, a renewed debate