2026 Finance Bill: A Fiscal Turning Point for Entrepreneurs and Investors
October 24, 2025 marks the beginning of debates in the National Assembly on the Finance Bill (PLF) 2026, following a tumultuous review in the finance committee. This text announces major changes directly affecting entrepreneurs, business leaders, investors, and private landlords. With the return of the exit tax, the overhaul of the Dutreil Pact, and the strengthening of a more stringent capital taxation, the French fiscal framework is set for a notable reorientation.
In this article, PRAX Avocats helps you understand the main measures of the PLF 2026 and assess their concrete impacts on your wealth strategy and business development.
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A Tense Macroeconomic Context
The finance committee examined the PLF 2026 from October 20 to 23 before rejecting the first part related to revenues. Parliamentary discussions are expected to be lively. Several symbolic, sometimes controversial measures reflect a fiscal tightening aimed at restoring budgetary balances after several years of increased public spending.
For entrepreneurs and investors, these adjustments are not trivial. They influence capital taxation, business transmission, and rental investment schemes, all essential levers for the growth of start-ups, SMEs, and wealth management holdings.
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The Dutreil Pact: A Refocusing on Family Transfers
The Dutreil Pact, an emblematic device for business transmission, is the subject of heated debate. According to the Budget Directorate, its cost is expected to reach 4 billion euros in 2026, down from 5 billion in 2024 — an unprecedented level making it the fourth most expensive tax niche.
In response to criticisms from the Court of Auditors, four amendments have been adopted to refocus the device on family transfers, its original purpose. This means:
- stricter control of arrangements aimed at circumventing its primary goal;
- a possible exclusion of wealth groups using the device as an optimization tool;
- and a desire to legally secure genuine intrafamily transfers.
For start-up or innovative business leaders, the message is clear: the use of the Dutreil Pact must align with a genuine entrepreneurial transmission logic. Tailored legal support becomes essential to anticipate these changes and secure conservation commitments.
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The Return of the Exit Tax: A Strong Signal to Mobile Taxpayers
An emblematic measure of Sarkozy's presidency, the exit tax makes a grand return in its pre-2019 version. It aims to tax latent capital gains on shares held by a taxpayer who transfers their tax residence abroad.
From now on, the tax administration will track shareholdings for a period of fifteen years after their departure. Each year, these taxpayers will have to declare that they have neither sold their shares nor left France solely for tax evasion purposes.
For founders of high-valuation start-ups, this measure requires careful re-evaluation of expatriation projects. Anticipating a sale or fundraising operation outside France will necessitate a rigorous analysis of the fiscal and legal consequences to avoid subsequent reassessment.
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The Flat Tax in Turmoil: Towards a More Progressive Capital Taxation
Another sensitive point of the bill is the flat tax (PFU) at 30% on capital income. Several amendments aim to increase its rate:
- +3 points proposed by the LIOT group,
- +3 to +10 points according to several LFI amendments,
- and even, from the Republican Right, the establishment of progressivity:
- 25% up to 100,000 euros,
- 30% between 100,000 and 300,000 euros,
- 35% beyond.
If these proposals were adopted, France would stand out from a rather opposite European trend, which tends to stabilize capital taxation to encourage productive investment.
For individual investors and innovative business leaders, the question is strategic: should one anticipate a re-evaluation of dividends or realize capital gains before the reform takes effect? Again, personalized legal and tax advice is crucial to adapt your remuneration policy or wealth strategy.
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Real Estate Investment: The Birth of a New Private Landlord Status
The government introduces a new private landlord status in the PLF 2026. A 2% tax depreciation on the value of a new rental property, along with incentives for the energy renovation of old housing, aims to revive a market that has been declining since the end of the Pinel scheme.
However, several industry players, including the French Building Federation, consider this depreciation rate "too low" to stimulate rental investment, which has fallen by 50% between 2024 and 2025.
This scheme could nonetheless interest entrepreneurs diversifying their assets. Its linkage with a corporate structure (such as a SCI or holding company) will require a detailed analysis in business law and real estate taxation to optimize the operation without increasing the tax burden on rental income.
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Life Insurance and Retirement Savings: Towards More Constraints
On the savings side, two changes deserve attention:
- The creation of a "living transmission" of life insurance, allowing part of one's contract to be given to children or grandchildren, with the same allowances as in a succession.
- The obligation to cash in one's retirement savings plan (PER) at the retirement age, ending the possibility of indefinite postponement.
These developments will encourage entrepreneurs and leaders to review their overall wealth transmission arrangements, especially in cases of accumulation between share capital, life insurance contracts, and corporate savings or retirement schemes.
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Key Takeaways
The PLF 2026 announces a major fiscal turning point, with a shift towards more control and a desire to refocus relief measures on their original objectives: genuine transmission, productive investment, and a revival of construction.
For innovative companies, leaders, and investors, this complexity calls for heightened vigilance. Each measure — whether it concerns the Dutreil Pact, the flat tax, or the private landlord status — should be integrated into a comprehensive legal and wealth strategy, tailored to your situation and objectives.
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How PRAX Avocats Supports You
In light of these developments, PRAX Avocats offers its expertise in business law, legal advice for companies, and wealth strategies for start-ups. Our tailored approach aims to secure your operations, anticipate legislative changes, and identify possible legal optimization levers.
For personalized legal support for your business project or to anticipate the impacts of the PLF 2026, contact PRAX Avocats.