France's 2027 budget bill: what changes for holding contributions, gifts and business transfers

By the Big4PM team · Published 13 November 2026 · 3 min read

In brief. France's 2027 budget bill would make the deferred gain from a contribution of shares to a holding company (article 150-0 B ter) taxable as soon as the holding shares are given away, for transfers made since 1 October 2026. The Dutreil pact is unchanged. On 4 November 2026 the National Assembly rejected the revenue part; the government's text goes to the Senate. Nothing is final yet.

Where the bill stands

The bill was filed on 1 October 2026. On 4 November the National Assembly rejected its first part (revenue) by 458 votes to 0, which counts as rejection of the bill at first reading. Amendments voted by MPs fall with it. The Senate now examines the government's original text, then a joint committee will seek agreement. The government may use article 49.3, and adoption by ordinance becomes possible after 70 days, from 17 December.

In practice, the measures below are those of the government's text. They may still change, but their effective date is already written into the text.

Holding contribution: a gift would no longer wipe out the gain

Today, an owner who contributes shares to a holding company before selling defers tax on the gain (see the guide). A gift of the holding shares can then pass the deferral to the children and, under conditions, cancel it. Article 5 of the bill removes this: any transfer, by gift or on death, would make the deferred gain immediately taxable in the donor's hands.

• Planned effective date: transfers made from 1 October 2026, before the vote. A gift made before year-end would not escape the measure if it is adopted.
• Payment in instalments: income tax could be paid over 5 years, on request and with guarantees. Social charges are not covered by the instalment option.
• Order of magnitude: a holding-contribution gain of €4.9m recorded in 2022 would become taxable for the donor on a gift of the holding in 2027.

The Dutreil pact reduces gift duties but has no effect on the tax due on the deferred contribution gain. Both must be modelled together.

Dutreil pact: unchanged by this bill

The bill does not amend article 787 B of the French tax code or the 75% exemption. The Dutreil remains subject to the 2026 finance law reform: individual commitment extended from 4 to 6 years and non-operating assets excluded (read our analysis).

Employee buy-outs: the 'Papin pact'

• Allowance on the retiring owner's gain raised from €500,000 to €1,000,000.
• Registration duty cut to 0.1% for an employee buying an SME, with at least 5 years' service in the last 10 and a management role.
• Extra depreciation on new equipment after the takeover: 30% for SMEs, 60% for micro-businesses.
• Sales covered: 1 January 2027 to 31 December 2029, with a 5-year holding requirement.

Cash gifts: a window in the first half of 2027

From 1 January to 30 June 2027, a cash gift to a descendant under 50 would be taxed at a flat 6% up to €100,000 per donor and donee. The article 790 G exemption would rise from €31,865 to €50,000.

What we advise now

1. List existing deferrals: contribution date, amount of the gain, reinvestment made, planned gift.
2. Do not rush a year-end gift to 'get in first': the 1 October 2026 effective date prevents it if the text is adopted.
3. Model two scenarios, text adopted and text dropped, in tax and five-year cash terms, before choosing between gift, sale or waiting.
4. Wait for the final text, expected in December, before any irreversible step, and validate the structure with your notary and tax lawyer.

This article is general information. It is not investment, legal or tax advice. The rules quoted must be checked by your advisers before any decision.