2026 Finance Law: Key Amendments Impacting Businesses and Holdings to Remember
As the finance law for 2026 continues its parliamentary journey in mid-January, several tax amendments are particularly drawing the attention of business leaders, investors, and family holdings. Behind the technicality of the texts, the stakes are concrete: control of the tax burden, wealth management, and regulatory anticipation.
This article, written by PRAX Avocats, a firm specializing in legal and tax support for start-ups and innovative companies, offers a clear and structured reading of these developments.
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1. General Context: A 2026 Budget Under Constraint but Focused on Clarification
The draft finance law for 2026 is set against a tense budgetary context. The government aims to stabilize public finances while adapting taxation to new economic challenges: the rise of holding structures, taxation of dormant assets, ecological transition, and territorial attractiveness.
Ongoing discussions in Bercy and the Assembly show a desire to simplify certain rules, sometimes at the cost of eliminating provisions deemed too costly or unclear. The proposed measures—from the corporate tax surcharge to the tax on holdings—reflect a clear direction: refocusing taxation on genuinely productive assets.
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2. Taxation of Businesses and Holdings: Maintaining Pressure but Targeted Tightening
a. The New Tax on Non-Operational Assets of Holdings
Article 3 of the draft law introduces a tax on non-operational assets held by wealth management holdings. The stated goal is to tax structures concentrating real estate or financial assets not mobilized in economic activity.
Amendment No. 3455 provides several important clarifications:
- Definition of Control: henceforth, a person or company holding directly or indirectly more than 50% of financial or voting rights will be considered as holding 100%.
This includes chains of ownership, shareholder agreements, and even certain intermediate vehicles located abroad.
- Restriction of Exemptions: specific regimes (venture capital companies, SIIC, OPC) are excluded from any unjustified deduction, intelligently refocusing the tax on true wealth structures.
- Clarification on Intra-Group Debts: loans between controlled companies cannot be deducted to reduce the taxable value of properties.
This tax, which is now set to take effect for financial years ending from 2026, will have significant consequences for the legal structuring of family groups and start-up holdings in the maturation phase.
Our advice from PRAX Avocats: it is advisable, from now on, to map the assets of holdings and anticipate the application of this tax, especially for hybrid structures combining operational participation and wealth holding.
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b. Exceptional Contribution on Profits of Large Companies
Article 4 of the same text provides for the temporary return of a surcharge on profits, limited to very large groups. The threshold for liability would be raised to 1.5 billion euros in revenue, effectively protecting mid-sized companies and growing scale-ups.
The proposed rates are staggered:
- 12% for the first financial year (after December 31, 2025),
- 10.3% for the second.
The expected yield, around 6.3 billion euros, will help maintain budgetary balance while preserving a certain neutrality for intermediate players.
Impact for growing start-ups and holdings: indirectly limited, but this measure confirms the trend towards strengthening “anti-rent” taxation. Companies that exceed group or tax integration thresholds will need to monitor the qualification of their profits.
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c. Deductibility of Interest: Towards a More Economic Approach
Another notable development, introduced by Article 4 ter (Amendment No. 3462), concerns the deductibility of interest paid to minority partners.
From now on, it is the market price criterion, rather than a fiscally capped rate, that will guide deductibility. In other words, if a company pays a partner interest corresponding to the rate actually observable in the market, this charge will remain deductible.
This change, aimed at securing certain intra-group financing, will apply retroactively to financial years ending from December 31, 2025.
For start-ups financed by their founders or investment holdings, the harmonization is welcome: it finally recognizes the economic logic of these provisions.
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3. Real Estate and Wealth Taxation: A Prudent Refocusing
a. Maintenance of the SIIC Regime and Rationalization of Local Taxes
In the real estate sector, several adjustments aim to preserve the balance between incentive and control:
- Listed real estate investment companies (SIIC) will remain exempt from the additional tax known as “Pillar 2” (Article 26), in order to maintain the competitiveness of the French regime against its European counterparts.
- Article 27 ter provides for the merger of taxes on vacant housing (TLV and THLV) into a single, more readable tax, benefiting municipalities. The goal is to rationalize a tax system that has become too complex and ineffective.
b. Better-Targeted Real Estate Incentives
The government has, however, proposed the elimination of certain provisions deemed too costly or poorly calibrated:
- Elimination of the extension of the old PTZ (Article 12 quinquies) for operations in Real Solidarity Lease (BRS);
- More precise targeting of rental depreciation in the old sector, reserved for heavy rehabilitations (Article 12 octies).
The objective is twofold: refocus aid on productive investment and limit the inflationary effect of incentive measures for partial renovations.
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4. Tax Credits and Specific Provisions: Rationalization and Coherence
This year, tax credits are undergoing significant refocusing:
- The tax credit for housing adaptation (Article 9 sexies) is disappearing in favor of the unified “MaPrimAdapt’” portal, which is simpler and more unified.
- The doubling of the tax credit ceiling for animated films (Article 24 ter) is eliminated due to excessive budgetary costs.
In this context, companies should expect fewer sector-specific niches, but more cross-cutting measures focused on innovation or digital transition.
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5. Key Takeaways for 2026: Technical Measures, a Clear Direction
In summary:
- The refocusing of taxation on genuinely productive assets is confirmed;
- Wealth management holdings must anticipate the future tax on non-operational assets;
- Start-ups and mid-sized companies remain largely protected from the corporate tax surcharge but must remain vigilant regarding the qualification of their financial income;
- The real estate sector is undergoing a rationalization of advantageous provisions, in a sense of simplification.
The guiding thread remains clear: clarify, refocus, empower. For business leaders, this means that the legal and tax structure can no longer be left to chance. It must be adjusted in light of the new rules, even before they come into effect.
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Conclusion: Anticipate and Structure Your 2026 Tax Strategy Now
The tax developments in the finance law for 2026 reflect a paradigm shift: taxation is becoming more selective, more pragmatic, and focused on creating real value.
For leaders as well as investors, anticipation is now key.
At PRAX Avocats, we support start-ups, SMEs, and holdings each year in the legal and tax structuring of their projects: setting up holdings, optimizing intra-group financial flows, supporting fundraising, restructuring operations, or wealth engineering.
Contact the firm now to conduct a preventive diagnosis and identify the optimization levers suited to your situation.
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