France 2027 Finance Bill: Proposed reforms to business succession tax

The 2027 Finance Bill (PLF) in France includes proposed reforms to the 'apport-cession' mechanism under Article 150-0 B ter of the General Tax Code, which governs how business owners transfer companies. While the initial text sought to end the deferral of capital gains tax during gratuitous transfers (such as donations or successions), recent parliamentary amendments have significantly narrowed the scope of these changes.

An amendment adopted by the finance committee aims to preserve current tax advantages for entrepreneurs who reinvest proceeds into economic activities. Specifically, the amendment proposes that succession of holding company shares would no longer trigger immediate taxation, maintaining the status quo. In the case of donations, the tax deferral would only be terminated if the holding company sells the contributed shares within eight years of the contribution.

Other adjustments include allowing the loss in value of shares since the contribution to be offset against deferred capital gains, extending the payment plan from five to ten years, and neutralizing certain intermediary operations like mergers or splits. The revised regime is expected to apply to transfers occurring from October 1, 2026.