On the evening of 8 October 2026, the finance committee of France’s Assemblée nationale voted for a new tax aimed squarely at family wealth: 2% a year on the portfolio securities held by family holding companies. The amendment came from Charles de Courson, a deputy for the Marne from the small Liot group. Capital magazine’s example: a holding with €1 million of such securities would pay €20,000 a year, whether markets rise or fall.
The headline is bigger than the legal effect. The next evening, the same committee rejected the entire revenue part of the 2027 budget bill. The plenary debate that opens on 13 October starts from the government’s text, which contains no such tax. For it to exist, deputies would have to vote it again in the chamber, and it would then have to survive the Senate and the final budget. Still, it shows families with a French holding where the political pressure is.
What a family holding is
In France, a “holding patrimoniale” is a company, usually subject to corporate tax, through which a family owns its assets. It often holds the family business, but over time it may also build up a portfolio of listed shares, bonds and funds. Money that stays inside is taxed at the company level, and personal tax on dividends only arrives when cash is paid out to family members. For a family that does not need the income, that wait can last decades. We described this building block in Holding Structures in Plain English.
That gap keeps drawing fire. When it proposed a holding tax in 2025, the government said it wanted to correct the under-taxation of income kept, undistributed, inside companies controlled by a few people.
What the amendment says
Amendment I-CF1706 was filed on 4 October by Charles de Courson, Jean-Pierre Bataille and Michel Castellani.
- Who pays. A “family holding”: a company whose main purpose is to hold and manage stakes in other companies, in which one family holds at least a third of the financial or voting rights, directly or indirectly. The family includes the person, a spouse or partner, parents and grandparents, children and grandchildren, and brothers and sisters.
- What is taxed. “Titres de placement”, or portfolio securities: shares or debt of other companies held for income or capital gains, with no intention of lasting influence or control. The tax is 2% of their net value on the balance sheet at year end, collected like corporate tax.
- What is not. “Titres de participation”: stakes held to control or influence a company, as French tax law defines them. Broadly, these are long-term strategic holdings, and stakes of 5% or more can qualify when booked that way. A holding that owns 60% of the family firm would pay nothing on that stake, but would pay on its listed shares and funds.
- What is missing. The text sets no euro threshold and no start date.
A charge on capital, not on income, bites hard. On a portfolio earning 4% a year, 2% takes half of the return before any other tax.
Why France keeps coming back to holdings
This is the second attempt in two budgets. In October 2025, the government proposed a 2% yearly tax on the non-business assets of holding companies, cash included. By the time the 2026 finance law was promulgated on 19 February 2026, it had shrunk to a 20% tax on a short list of luxury assets, such as yachts, private planes, racehorses, wine, jewellery and homes used by the family. It applies to holdings with at least €5 million of assets, at least half owned by one person or family, and mainly passive income. Cash and securities were left out. It first applies to years closing from 31 December 2026.
De Courson’s amendment goes after what was dropped: the financial portfolio. Its explanatory note says the aim is to clarify what counts as a portfolio security and to curb the practice of keeping large financial portfolios in non-operating structures that are taxed more lightly.
A second front is succession: the 2027 bill would stop deferred capital gains tax from disappearing when holding shares are given or inherited (see our post on the apport-cession change).
The rest of the picture
- Share buybacks. The same evening, committee chairman Éric Coquerel (LFI) won a vote to cut the turnover threshold for France’s tax on share buybacks from €750 million to €100 million, according to LCP. That would bring much smaller companies into the tax.
- Wealth tax. The 2027 bill contains no reform of the IFI, France’s wealth tax on property, which starts at €1.3 million of net property. On 31 October 2025, deputies voted to turn the IFI into a tax on “unproductive wealth”, but the final 2026 law, adopted on 2 February 2026, left it unchanged. Taxing financial wealth inside holdings is a narrower route into the same debate.
- The vote that matters. On 9 October, the committee rejected the revenue part of the bill by 31 votes to 3, with 2 abstentions. The plenary debate runs from 13 October, with a vote on the revenue part planned for 20 October and on the whole bill on 17 November, before it goes to the Senate.
A fair caveat
Committee votes are not law, and this one sits in a part of the bill the committee then rejected as a whole. If it returns, it may be rewritten, given a threshold, or dropped. The line between portfolio and controlling stakes is technical.
Five lessons to take away
- Committee votes are signals, not law. This one needs a new vote in the chamber, then the Senate.
- Know what your holding owns. The split between controlling stakes and portfolio securities could decide the bill.
- Measure a tax on assets against the return. At 2% a year, the charge does not depend on whether the portfolio made money.
- One tax advantage is a fragile reason for a structure. France has now tried to tax holding assets in two budgets in a row.
- Read the definitions before the rate. Who counts as family and what counts as control decide who pays.
Questions to bring to your advisors
What share of our holding is controlling stakes and what share is portfolio securities, in accounting terms? Does one family hold a third or more of it? What would 2% a year cost us, and how does that compare with paying dividends out and investing personally? These are questions to bring to your lawyers and tax advisors, not advice.