France's National Assembly finance committee adopted a new 2% annual tax on family holding companies on 8 October 2026, then rejected the entire revenue section of the 2027 budget containing it on 9 October. Under France's Constitution, that second vote resets floor debate to the government's original text, which does not include the tax. If you hold assets inside a French family holding company, or are weighing whether to set one up, nothing about your structure changed on 8 October. Something else did change earlier in the year, and that part is already in force.
What amendment I-CF1706 would have done
Deputy Charles de Courson (LIOT) filed amendment I-CF1706 to the 2027 Finance Bill (no. 3210) on 4 October 2026, with two co-signatories. It would create a new article, 235 ter ZD bis A, in the General Tax Code: an annual tax of 2% on the net value of "titres de placement", investment securities held for yield or capital growth rather than for control of a business, sitting in a holding company's assets at the end of its financial year. The amendment defines a "family holding" as a company in which one family, a person plus their spouse, civil partner or long-term cohabiting partner, ancestors, descendants and siblings, holds 33.33% or more of the financial or voting rights, directly or indirectly. The finance committee adopted the amendment on the evening of 8 October 2026.
Why it does not apply, at least for now
The next day, 9 October 2026, the same committee voted 31 against, 3 in favour and 2 abstentions to reject the whole revenue section of the budget, the section the new tax belonged to, after around 200 amendments adopted that week left a provisional €9.6bn hole in the government's revenue plan and pushed the rapporteur general's deficit estimate to 5.35-5.4% of GDP against a 5% target. Under article 42 of the French Constitution, a finance bill's floor reading proceeds on the government's original text, not the committee's amended one. The Assembly opened that floor debate on 13 October 2026, with a solemn vote on Part 1 scheduled for 20 October. Unless de Courson's amendment, or something like it, is refiled and passed again on the floor, it does not become law from this round.
This is not the first time, and one version already passed
An almost identical amendment, CF390, was filed on 5 January 2026 and rejected by the same committee on 8 January 2026, during the 2026 budget process. The idea did not die there. Article 7 of the 2026 Finance Act, Law No. 2026-103 of 19 February 2026, created article 235 ter C of the tax code: a 20% annual tax on the market value of non-operational assets held inside a holding company, when the company's total assets reach €5m or more, one individual holds 50% or more of the voting or financial rights, and passive income makes up more than half of total income. That tax is in force now and first applies to financial years ending on or after 31 December 2026. It targets a narrower, larger-asset slice of holding companies than the October amendment aimed at, and it did not require the vote that failed on 9 October, because it passed earlier in the year under a constitutional mechanism that does not require a floor vote at all.
France exit tax: a separate cost if you are thinking about leaving instead
Some people reading about a new tax on their holding company think first about relocating rather than restructuring. That decision runs into a different mechanism entirely: the French exit tax under article 167 bis of the tax code. It applies to someone who has been a French tax resident for at least six of the preceding ten years and holds securities worth more than €800,000, or at least 50% of a company, when they move their tax residence abroad: unrealised capital gains on those holdings are taxed at a combined rate of 31.4% on the day residence changes, though deferral is available and the liability can lapse after two years without a sale, or five years above €2.57m. The exit tax is not new, and it is not connected to the 2% amendment discussed above: a holding company itself staying French and taxed under article 235 ter C, and an individual leaving France while holding qualifying securities, are two different triggers with two different rules.
What this means if you hold, or are planning, a French holding company
The only new tax currently in force on this category of asset is the 20% charge under article 235 ter C, and it only reaches holding companies with €5m or more in assets, majority individual control, and mostly passive income. A holding company below that threshold, or with a genuine operating business rather than passive securities, is not affected by either measure. Whether the 2% amendment comes back in a form that reaches smaller or differently structured holdings is a live question through the 20 October floor vote and beyond, not a settled one. ETERAX explains what the rules in force actually require, structures a holding, Dubai, Singapore, Netherlands or elsewhere, around them, and implements the paperwork. Whether and how to restructure, and whether to stay a French tax resident at all, is the client's decision.
- Assemblée Nationale, amendment n°I-CF1706 to PLF 2027 (no. 3210). assemblee-nationale.fr
- Assemblée Nationale, amendment n°CF390 to PLF 2026 (no. 2247), filed 5 January 2026. assemblee-nationale.fr
- Légifrance, Article 7, Loi n° 2026-103 du 19 février 2026 de finances pour 2026 (article 235 ter C CGI). legifrance.gouv.fr
- Legifiscal, "PLF 2027 : la commission des finances rejette la partie recettes après avoir creusé le déficit d'environ 10 Md€", 9-10 October 2026. legifiscal.fr
- Le Club des Juristes, "Budget 2027 : le projet arrive devant l'Assemblée nationale mardi 13 octobre". leclubdesjuristes.com
- Assemblée Nationale, deposit header for Projet de loi de finances pour 2027, n° 3210, registered 1 October 2026. assemblee-nationale.fr
Common questions
Is France's wealth tax on holding companies now law?
Two different measures are involved. A 20% annual tax on passive or luxury assets inside larger holding companies, article 235 ter C of the tax code, is law now and first applies to financial years ending on or after 31 December 2026. A separate, broader 2% tax on investment securities inside family holdings, amendment I-CF1706, was adopted by committee on 8 October 2026 and then erased the next day when the committee rejected the whole revenue section of the budget. It is not currently law.
What is the difference between France's wealth tax and France's exit tax?
France's general wealth tax (ISF) was abolished in 2018. The measures discussed here tax assets inside a holding company that stays French. The exit tax, article 167 bis of the tax code, is a different mechanism: it taxes unrealised gains on qualifying securities when a French tax resident of at least six of the last ten years moves their tax residence abroad, at a combined 31.4% rate above an €800,000 or 50%-ownership threshold.
Who would the 2% holding company tax have affected if it had passed?
As filed, amendment I-CF1706 would have applied to "family holdings", companies where one family holds 33.33% or more of the financial or voting rights, taxing 2% of the net value of investment securities, assets held for yield or appreciation rather than business control, at each financial year end.
Why did the committee reject its own amendment one day after adopting it?
It did not reject the amendment by name. It rejected the entire revenue section of the budget, as amended by roughly 200 changes adopted that week, after the rapporteur general estimated those changes together would cut revenue by about €9.6bn and raise the deficit to 5.35-5.4% of GDP against a 5% target. Because French procedure sends floor debate back to the government's original text once the committee's version is rejected, every amendment adopted that week, not just this one, fell away for the floor stage.
What should someone with a French holding company do now?
Check whether article 235 ter C currently applies: it only reaches holdings with €5m or more in assets, majority individual control, and mostly passive income, from financial years ending on or after 31 December 2026. The broader 2% amendment is not in force and may or may not return in the floor debate scheduled through 20 October 2026. ETERAX sets out what current law requires and structures accordingly; the decision on whether and how to restructure stays with the client.