Taxation of management package gains above three times the company's performance
Article 93 of the 2025 Finance Act creates Article 163 bis H of the General Tax Code: net gains made by employees or managers on shares acquired in return for their duties are taxed as employment income, except for the portion not exceeding three times the company's financial performance, which remains taxed as a capital gain. A 10% flat employee contribution to the family allowance fund is created.
Measure originators
No official estimate found for this measure.
Measure impact
Concerns managers and executives holding management packages, for sales, conversions or rentals from 15 February 2025. Article 92 separately amends the taxation of start-up share warrants (BSPCE) for shares subscribed from 1 January 2025.
Official references
Sources
Procedure timeline
Follow the progress of this fiscal measure through the different stages of the parliamentary procedure.
Administrative implementation
Entrée en vigueur de la mesure et mise en œuvre par l'administration
President of the Republic signature
Publication au Journal officiel
Possible referral to Constitutional Council
Décision de conformité / censure partielle
Debate and vote
National Assembly has the final say
Si échec CMP
Joint committee
Désaccord éventuel
Debate and vote
Council of Ministers
Validation interne