Family Office in France: Rules, Costs and Tax in 2026
France has no family office law or licence: the report of the 118th Congress of French Notaries (2022) says the activity is regulated by no text in France and that most family officers adopt the status of financial investment adviser (CIF), while the AMF approves portfolio management companies and the professional associations of CIFs. Families face full French taxation: income tax up to 45% plus contributions on high incomes, a flat tax of 31.4% on investment income since 1 January 2026, a real estate wealth tax (IFI) on net property above EUR 1.3 million, and inheritance tax of 5% to 45% for children above EUR 100,000 each, eased for family companies by the Dutreil regime. The 2026 finance law (19 February 2026) added a 20% tax on certain luxury assets held by holding companies with at least EUR 5 million of assets, and the 2027 budget bill, under debate in the National Assembly in October 2026, contains proposals on gains on shares contributed to holding companies (apport-cession) and on family cash gifts; none of them is law. [1, 2, 3, 4, 5, 6, 7, 8, 9]
Best for: Families who live in France or own French companies and want to pass them on under the Dutreil regime (75% of the value of the shares exempt from gift and inheritance tax, with holding commitments), and who accept French income, wealth and inheritance taxes and frequent budget changes to the taxation of holding companies.
At a glance
| Licence | No family office law (notaries); portfolio management for third parties needs approval reported |
|---|---|
| Minimum wealth | No wealth minimum found; no French text regulates family offices reported |
| Who counts as family | Not defined; holding tax control test counts spouse, partners, ascendants, descendants reported |
| Serving several families | No dedicated licence: CIF status (most offices) or AMF portfolio manager approval reported |
| Law and courts | Civil Code succession; AMF; national taxes in the General Tax Code |
| Substance | No family office rule found; AMF-approved managers need an approved activity programme reported |
| Holding vehicles | Holding companies (20% tax on luxury assets from 2026); life insurance outside the estate reported |
| Corporate tax | 25% (15% on first EUR 42,500, small firms); dividends from 5% stakes exempt bar 5% costs |
| Family office tax | No family office regime; 20% tax on luxury assets of holdings with EUR 5 million or more |
| Personal income tax | 45% top rate plus 3% to 4% levy, 20% minimum tax; 31.4% flat tax on investment income |
| Inheritance tax | Spouse and PACS partner exempt; children 5% to 45% above EUR 100,000 each |
| Wills and succession | Children's reserve 1/2 to 3/4 of estate; claim on French assets if foreign law has none reported |
| Residence | Talent investor permit: EUR 300,000 in fixed assets plus jobs, up to 4 years; visitor visa |
| Time to set up | No official figure found |
| Official fees | No official figure found |
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Licence and who qualifies
How is a family office licensed in France?
No family office licence or registration was found: the report of the 118th Congress of French Notaries (2022) says the family office activity 'is regulated by no text in France' and that most family officers adopt the financial investment adviser (CIF) status of article L.541-1 of the Monetary and Financial Code. The AMF says that portfolio management for third parties is an investment service that, when provided on a regular basis, only an investment services provider approved for that service may provide, with exceptions limited to those listed in article L.531-2 of the Code; the same AMF Q&A says the CIF regime does not apply to persons that provide investment services only to legal entities that control them, that they control or that are under the same control (AMF DOC-2006-23, 2019). No AMF statement or official text was found on whether an office that manages the money of one family's members needs approval, and article L.531-2 itself could not be opened on Légifrance. [1, 2, 12, 13]
Reported by the sources named, not confirmed by an official source.
What is the minimum wealth for a family office in France?
No minimum family wealth in the sources checked: no French text regulates family offices (118th Congress of French Notaries, 2022), and no wealth condition appears in the AMF sources opened. The EUR 5 million asset threshold of the 2026 holding company tax and the EUR 1.3 million threshold of the real estate wealth tax (IFI) are tax thresholds, not conditions for a family office. [1, 2, 4, 5, 13]
Reported by the sources named, not confirmed by an official source.
Who counts as family?
Not defined: because no French text regulates family offices, none says who counts as the family (118th Congress of French Notaries, 2022); the notaries' report quotes the French Family Office Association (AFFO), which defines a family office as an organisation of persons offering advice and services to families. For comparison, when testing whether a family controls a holding company, the 2026 holding tax counts the rights of the spouse, PACS partner, cohabiting partner, ascendants, descendants and siblings, according to Lazard Frères Gestion (Actu-Juridique). [1, 14]
Reported by the sources named, not confirmed by an official source.
Can one office serve several families?
No dedicated multi-family office licence was found. An office serving several families is regulated by what it does: discretionary portfolio management for third parties is an investment service provided by portfolio management companies approved by the AMF (SGP), and advice falls under the financial investment adviser (CIF) status, whose professional associations the AMF approves; the 118th Congress of French Notaries (2022) says most family officers in France adopt CIF status. The AMF monitored about 700 portfolio management companies in 2023 (AMF key figures), and 7,013 CIFs were registered at the end of 2024, each a member of one of four AMF-approved associations (AMF CIF key figures, December 2025). [1, 2, 12, 13, 15]
Reported by the sources named, not confirmed by an official source.
Law, substance and vehicles
Which law and courts apply?
Income tax, corporate tax and gift and inheritance tax are national taxes set in the General Tax Code (CGI) and explained in the tax administration's official bulletin (BOFiP). Financial regulation is national: the AMF approves portfolio management companies (SGP) and the professional associations of financial investment advisers (CIF). Succession is governed by the Civil Code, whose article 913 protects children with a reserved share, according to notaries. [2, 3, 7, 13, 16]
What substance is required?
No office, staff or spending rule for a single family office was found, since no French text regulates family offices (118th Congress of French Notaries, 2022). A portfolio management company approved by the AMF must have a programme of activity for each activity or service it intends to provide, and must have it extended before using new instruments, 'from the first euro' (AMF guide DOC-2012-19). [1, 13]
Reported by the sources named, not confirmed by an official source.
Which holding vehicles are available?
Families commonly use holding companies subject to corporate tax: the Senate finance committee notes that 'animating' holding companies (holdings animatrices) can qualify for Dutreil relief, while mainly passive holdings with at least EUR 5 million of assets are within the 2026 holding company tax. Life insurance (assurance-vie) is used to pass capital to named beneficiaries outside the estate and outside the children's reserved share, unless the premiums were manifestly excessive (article L.132-13 Insurance Code), according to notaries. [5, 7, 17, 18]
Reported by the sources named, not confirmed by an official source.
Tax
What is the corporate tax rate?
Corporate tax is 25% for financial years opened from 1 January 2022; companies with turnover up to EUR 10 million whose fully paid-up capital is at least 75% owned by individuals pay 15% on the first EUR 42,500 of profit, and companies with turnover of at least EUR 7.63 million pay a 3.3% social contribution on corporate tax above EUR 763,000. A temporary exceptional contribution on large companies applies to the first two financial years closing from 31 December 2025, calculated on corporate tax due at 20.6% (41.2% from EUR 3 billion of turnover), for turnover of at least EUR 1 billion in the first year and EUR 1.5 billion in the second (extended by article 12 of the 2026 finance law). A family holding company excludes dividends from subsidiaries in which it holds at least 5%, except a 5% share of costs (1% in a tax group), and long-term gains on participations held at least two years are taxed at 0% with a 12% share of costs added back. [11, 19, 20, 21, 22]
Are there tax incentives for family offices?
No tax regime for family offices was found. Under the 2026 finance law, a 20% tax applies, for financial years closing from 31 December 2026, to the market value of certain luxury assets not linked to a professional activity, such as yachts, collection vehicles, racehorses and jewellery, held by holding companies controlled by individuals, with a threshold of at least EUR 5 million; cash, financial securities, active holdings and works of art are excluded (Ministry of the Economy). Deloitte Société d'Avocats and Lazard Frères Gestion (in Actu-Juridique) say the EUR 5 million is the market value of the company's assets, that the holding must earn mainly passive income (over 50% of operating and financial income), that control means 50% or more held by an individual together with close family (Lazard), and that homes kept for the shareholders' use, aircraft, wines and spirits are also taxed. [5, 14, 23, 24, 25]
Is there personal income tax?
Residents pay income tax: the scale for 2025 income (taxed in 2026) reaches 45% above EUR 181,917 per household share (part), after the 2026 finance law indexed it by 0.9%. High incomes also pay the exceptional contribution on high incomes (3% on reference income between EUR 250,000 and EUR 500,000 and 4% above, per the Senate finance committee, which says its thresholds are almost the same as those of the CDHR below) and, from 2025 income, a differential contribution (CDHR) that ensures a minimum average tax of 20% on reference income above EUR 250,000 (single) or EUR 500,000 (couple), which the 2026 finance law extended until the year the budget deficit falls below 3% of GDP. Dividends, interest and gains on securities bear the flat tax (PFU), 31.4% in total since 1 January 2026 (12.8% income tax and 18.6% social levies, per the Senate finance committee), after the social security financing law for 2026 raised the CSG on capital income from 9.2% to 10.6%: from 1 January 2026 for investment products and from 2025 income for patrimonial income, while property income, real estate gains, life insurance and home savings schemes (épargne logement) stay at 9.2% (impots.gouv.fr); the real estate wealth tax (IFI) applies to net property above EUR 1.3 million. The impatriate regime (article 155 B CGI) is only for employees and certain executives recruited from abroad who were not tax resident in France in the previous five years: until 31 December of the eighth year after taking up duties it exempts the impatriation bonus and half of certain foreign investment income and gains, and people who become resident after at least five years of non-residence pay IFI only on French property until 31 December of the fifth year. [3, 4, 5, 17, 23, 26, 27, 28]
Is there inheritance or estate tax?
Inheritance and gift tax applies nationally. A surviving spouse or PACS partner is fully exempt on death; each child (and each parent) has an allowance of EUR 100,000 and then pays 5% to 45%, with 45% above EUR 1,805,677, while siblings pay 35% or 45% after EUR 15,932, relatives to the fourth degree 55% and others 60% (Ministry of the Economy). For gifts, the EUR 100,000 allowance per parent per child is available again once earlier gifts are more than 15 years old, and gifts to a spouse or PACS partner have an allowance of EUR 80,724 (impots.gouv.fr). The Dutreil regime exempts 75% of the value of shares in a company passed on by gift or at death, with a collective holding commitment of at least two years and an individual commitment raised from four to six years for transfers from 21 February 2026, when the 2026 finance law also excluded certain luxury assets not used exclusively for the company's operating activity (BOFiP). Life insurance is taxed separately: on premiums paid before age 70, EUR 152,500 per beneficiary is exempt, then 20% on the first EUR 700,000 of the taxable amount and 31.25% above; on premiums paid after 70, EUR 30,500 in total is exempt and the rest of the premiums (not the gains) bears inheritance tax; a spouse or PACS partner pays nothing, according to notaries. [6, 7, 10, 18, 29]
Succession and residence
How do wills and succession work?
Children are protected heirs: under article 913 of the Civil Code the reserved share is half the estate with one child, two thirds with two and three quarters with three or more, according to notaries. Since a law of 24 August 2021 (deaths from 1 November 2021), if the deceased or a child is an EU national or resident and the foreign law governing the succession has no mechanism protecting children, each child can take compensation from assets located in France; the EU Succession Regulation (650/2012) usually applies the law of the last habitual residence. CRIDON Nord-Est (10 June 2026) says the European Commission closed a complaint against this rule on the understanding that English family provision counts as a protective equivalent, so the rule rarely applies. [16, 30]
Reported by the sources named, not confirmed by an official source.
Can the family get residence?
The 'Talent - economic investor' residence permit (passeport talent) is open to foreign investors who make, or commit to make, an investment of at least EUR 300,000 in tangible or intangible fixed assets in France, personally, through a company they manage or through a company in which they hold at least 30% of the capital, and who create or maintain jobs, or commit to, within four years of the investment (Business France). It lasts up to four years and is renewable; the spouse and minor children can join (Business France), family members receive multi-year permits, and the permit lets the spouse and children from their 18th year work (France-Visas); after five years of regular, uninterrupted residence the investor may apply for a renewable 10-year card. Business France lists an administrative fee of EUR 300, stamp duty of EUR 50 and EUR 99 for the long-stay visa. People who will not work can apply for a long-stay visitor visa (a visa serving as a residence permit, validated online after arrival), committing not to work and proving resources, accommodation and medical cover; France-Visas gives no minimum amount and says requirements depend on the country of residence or nationality. [31, 32, 33]
Time and fees
How long does set-up take?
Not found in official sources.
What are the official fees?
Not found in official sources opened. No family office licence fee exists because no family office licence was found; commercial register and AMF approval fees were not found. [1]
Pros and cons
Pros
- A surviving spouse or PACS partner pays no inheritance tax, and the Dutreil regime exempts 75% of the value of company shares passed on by gift or at death, subject to holding commitments (six years individually for transfers from 21 February 2026).
- A family holding company excludes dividends from stakes of at least 5% except a 5% share of costs, and long-term gains on participations held at least two years are taxed at 0% with a 12% share of costs added back.
- An investor residence route is open: the Talent economic investor permit, for at least EUR 300,000 in fixed assets with jobs created or kept, lasts up to four years and is renewable, the spouse can work, and a 10-year card can be requested after five years.
Cons
- No family office law or licence: an office serving several families uses general regimes (CIF status or AMF approval as a portfolio management company), and no official text was found that puts one family's own office outside licensing.
- High personal taxes: income tax up to 45% plus a 3% or 4% contribution and a 20% minimum tax on high incomes, and 31.4% on investment income since 1 January 2026; children pay 5% to 45% inheritance tax above EUR 100,000 each.
- Holding companies are a recurring budget target: a 20% tax on certain luxury assets of holdings applies from financial years closing on 31 December 2026, and the 2027 budget bill, still under debate, contains a proposal on gains on shares contributed to holding companies (apport-cession).
