As wealth taxation resurfaces in public debate, a recently published figure by the DGFiP draws attention: according to the DGFiP Statistics Bulletin No. 45 on IFI 2025, nearly 13,300 households subject to the real estate wealth tax (IFI) would pay no income tax. An apparent paradox that raises questions about the coherence of our tax system and its impact on holders of old real estate assets.

For entrepreneurs, managers, or investors, understanding the relationship between income tax and wealth taxation is essential. Beyond the numbers, this data reflects a reality to anticipate: wealth taxation is evolving, and its interpretation requires rigorous legal support.

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1. A Finding that Fuels the Debate on Tax Equity

The data published by the DGFiP reveals a precise profile: households with an average real estate wealth of 2.4 million euros, an average IFI of 8,100 euros, and a median taxable income of 38,900 euros. Half of the primary declarants are over 68 years old.

These households often belong to a generation that acquired old real estate assets, whose value has significantly increased over the decades, without their current incomes following the same trend. Hence this atypical situation: an asset taxed on wealth, without sufficient resources to easily pay income tax… or sometimes even the IFI itself.

Contrary to some hasty interpretations, this is not about aggressive tax optimization, but rather the mechanical consequence of a dual taxation system: on one side income, on the other wealth.

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2. The Functioning of the IFI: A Distinct Wealth Logic

2.1. A Tax Focused Exclusively on Real Estate Value

Established in 2018 to replace the solidarity tax on wealth (ISF), the IFI targets net taxable real estate wealth exceeding 1.3 million euros. It does not take into account all financial assets (stocks, life insurance, professional investments), except for very specific exceptions.

The tax threshold and the progressivity of the scale mean that this tax affects a minority of households, often owners of high-value properties in tight markets.

2.2. Concrete Effects for Holders of Illiquid Assets

For many taxpayers, particularly heirs or retirees owning old buildings, this taxation poses a liquidity problem: their wealth is highly valued but non-productive of income. They thus find themselves having to sell assets or resort to borrowing to meet the IFI.

This issue also concerns entrepreneurs, often holders of real estate investment companies (SCI) or professional assets partially subject to the IFI. The question is not only about the amount to be paid but also about the legal and tax management of asset ownership.

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3. Implications for Entrepreneurs and Investors

3.1. Anticipating the Taxation of Ownership

When a company owns a real estate asset (offices, warehouse, commercial space) or when an entrepreneur owns a property through an SCI, it is essential to analyze the nature of ownership: is it a professional or personal asset? The appreciation of this distinction has a direct impact on IFI liability.

Similarly, the mode of financing (personal loan, capital contribution, property dismemberment) influences the evaluation of taxable wealth. A superficial approach to these rules can lead to avoidable overtaxation.

3.2. Balancing Yield, Transmission, and Taxation

Beyond the simple annual payment of the IFI, entrepreneurs must consider a coherent wealth holding strategy:

Should a property be retained in a corporate structure?

Can reinvestment in innovative start-ups or professional private equity funds (FPCI) contribute to better optimization?

How to articulate wealth protection and preparation for transmission?

A legal counsel in business law or in wealth tax management allows for a comprehensive approach to these choices, integrating both cash flow constraints and future valuation perspectives.

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4. A System Under Review: Towards a Reform of Wealth Taxation?

The fact that 13,300 wealthy households in terms of wealth pay no income tax fuels political reflections on a better overall progressivity of the tax system. A parliamentary inquiry commission is currently underway to study the opportunity to adapt the taxation of high wealth.

For managers and investors, this perspective calls for active vigilance:

IFI scales could be adjusted or revalued.
Rules for debt deductibility or exemptions for professional assets could evolve.
Interactions between the IFI and capital income could be reassessed.

In this changing context, tailored legal and tax support becomes more than ever a strategic management tool. Taxation developments are not just a constraint: they can also open up opportunities for arbitration and structuring.

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5. Tailored Support from PRAX Avocats

At PRAX Avocats, we have been supporting start-ups, entrepreneurs, and managers for many years in the legal and tax structuring of their professional and personal wealth. Our approach intersects several disciplines: business law, labor law, intellectual property, and taxation applied to businesses and their leaders.

We intervene at every stage:

Wealth and legal audit of existing structures (holding, SCI, holding subsidiaries)

Optimization of asset holding in compliance with tax rules

Anticipation of transmission and implementation of protection strategies for managers and their families

Our goal is clear: to protect and enhance your wealth while ensuring rigorous compliance with tax and legal obligations.

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Conclusion: A Balance to Rethink Between Income, Capital, and Taxation

The debate around the IFI highlights a simple but often overlooked reality: wealth is not only measured in income but also in held assets. In a context of reevaluation of tax models, entrepreneurs and holders of real estate wealth have every interest in anticipating these developments with a strategic vision and expert support.

The challenge is not to escape tax but to understand its logics to better adapt to it.

Contact the firm

To assess the impact of these developments on your wealth situation or that of your business, contact PRAX Avocats for tailored legal and tax support.

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Integrated keywords: start-up lawyer, business legal advice, business law, intellectual property, labor law, IFI, wealth taxation, taxation of start-ups, legal structuring.

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