PLF 2026: an announced tightening of wealth taxation to anticipate now.
The fiscal autumn of 2025 is shaping up to be busy. As the Draft Finance Bill (PLF) for 2026 is under review, the Finance Committee of the National Assembly has adopted a series of amendments marking a shift towards stricter regulation of wealth taxation.
For entrepreneurs, leaders, and project holders, these measures could have a significant impact on the management of their holdings, business transfers, or capital reorganizations.
This article analyzes the main orientations of the text and their practical implications, with insights from PRAX Avocats, a firm specializing in business law and support for start-ups and business leaders.
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A Context of Assumed Fiscal Toughening
For several years, lawmakers have sought to limit what they consider “abusive” optimization strategies in the management of professional or private wealth.
The PLF 2026 fully aligns with this logic: encouraging fiscal stability in France and locking down the relief mechanisms used during expatriations, successions, or business sales.
While these amendments voted in the Committee are not yet final, they reflect a clear direction from Parliament. Vigilance is therefore required from now on.
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1. Exit Tax: The Return of the 15-Year Delay
The first strong signal comes from the reinstatement of the 15-year delay for the Exit Tax exemption.
This tax provision aims to tax unrealized capital gains when transferring tax residence outside France.
What Changes:
- Before Reform (since 2019): the exemption was obtained after 2 to 5 years of the taxpayer residing abroad.
- With the PLF 2026: this delay would be extended to 15 years, reverting to the rule prior to 2019 (amendments I-CF402 and I-CF732).
Concrete Implications:
- This measure hinders departures abroad motivated by tax considerations.
- For an entrepreneur holding a stake in their start-up, it imposes a prolonged tax link with France, making any short- or medium-term optimization difficult.
At PRAX Avocats, we advise leaders considering international mobility to assess the impact of this extension now, particularly on their fundraising or future sale projects.
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2. Holdings, Successions, and Contribution-Sale: The Hunt for Tax Leverage Effects
The text does not create a new tax on capital accumulated in holdings, but it profoundly modifies the evaluation and reinvestment rules, resulting in a tightening of maneuvering margins for leaders.
2.1 “Look-Through” Evaluation of Wealth Holdings
Amendment I-CF1463 establishes a so-called “look-through” approach: during a succession, the value of holding shares will be assessed based on the underlying assets, allowing only a maximum discount of 10% on non-operational assets.
Objective: reduce the gaps between declared value and actual value of the transmitted wealth.
For leaders who have structured their wealth through a holding, this implies:
- a potential increase in the taxable base during transmissions,
- the need to reevaluate existing schemes before any succession operation.
2.2 Reform of the Contribution-Sale Regime (Article 150-0 B ter)
The tax deferral regime, often used to allow an entrepreneur to reinvest after selling their company, is also revised upwards with amendment I-CF1379:
- the reinvestment threshold rises from 60% to 80% of the sale price,
- the reinvestment period is extended from 3 to 5 years.
These adjustments aim to limit minimal reinvestment strategies and to ensure real commitment to new economic projects.
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3. Dutreil Pact: A More Rigorous Framework for Business Transfers
The Dutreil Pact, a cornerstone of family business transfers, is not exempt from this movement.
Several amendments (I-CF1377 and I-CF1378) come to regulate the system.
Main Developments:
- Limitation to Operational Activity: only the value of assets directly linked to the company's activity would benefit from partial exemption.
- Extension of the Holding Period: the period would increase from 4 to 6 years, prolonging the obligation to hold shares to retain the tax advantage.
These measures reflect the legislator's desire to reserve the Dutreil advantage for actual transfers of active businesses, not for passive wealth structures.
Points of Vigilance:
For leaders preparing a transfer in the medium term, it becomes essential to anticipate:
- the new definition of eligible activity,
- the commitment duration to adapt in existing agreements.
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A Reform in Motion: Caution and Anticipation
At this stage (October 20, 2025), it should be noted that these amendments have been adopted by the Finance Committee, but must be confirmed in a public session.
The text may still evolve, but the direction seems clear: more transparency, less latitude for fiscal arbitration.
What to Do Now?
- Audit your wealth structure: holdings, shareholder agreements, ongoing Dutreil commitments…
- Review planned international mobility operations before the end of 2025.
- Anticipate the transfer or sale rather than suffer the reform in 2026.
PRAX Avocats regularly supports entrepreneurs, start-ups, and leaders in these types of arbitrations, integrating both legal, fiscal, and wealth aspects.
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In Conclusion: Prepare Rather Than React
The PLF 2026 confirms a fundamental trend: strengthening control over wealth and capital holding strategies.
Rather than seeing it as a hindrance, leaders can view it as an opportunity to optimize in full compliance, provided they act methodically and with anticipation.
The coming months will be decisive.
Starting today, a personalized analysis can secure your existing arrangements and adjust your wealth strategy before the effective implementation of the text.
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Contact the Firm
Do you want to assess the impact of the PLF 2026 on your structure or professional wealth?
Our lawyers specializing in business law and corporate legal advice, experts in supporting start-ups and leaders, guide you step by step.
Contact PRAX Avocats for tailored support suited to your situation.