While the calls to tax the highest assets multiply during budgetary debates, the prime minister drew a new tax taxes on Friday, a maquis of companies in which it is not always easy to meet.
The Head of Government said he proposed the creation of a “financial assets tax”, but not the Zucman tax that he considers “dangerous” for the economy and employment, specifying that the system would save the professional heritage.
What is a holder company?
It is a parent company that controls participations in other companies.
For example, Artemis, the Pinault family holding company, has actions at the Luxury Kering Group (Gucci, Yves Saint Laurent …) but also in the Christie’s house, The Puma Brand, Le Point Magazine or The Stade Rennais Football Club.
The legal form of the holder can vary (SAS, SARL, SA …), but its purpose is to maintain and guarantee the management of a portfolio of shares in other companies, for example.
Management methods allow distinguishing different types of holdings.
When it provides an operating and strategic role, and actively manages the portfolio it has by getting involved in the decision -making process of the company it has, we are talking about a company holding “animator”.
There are also “heritage” holdings, rather characterized by the passive management of the participations. Specifically, the structure will have participations and, above all, will collect the dividends that result from it, which can lead to an accumulation of resources.
If the government has not delivered details about the type of holding to which reference is made in its fiscal project, it seems that it is rather the last one that is attacked, in particular the family holdings characterized by the family ties of the shareholders.
What are the advantages of a holder company?
The creation of a holder can give tax advantages, but is essentially imposed on the normal corporate tax rate.
On the other hand, holdings benefit from the fiscal regime of the mother and subsidiary companies, known as “mother-daughter”, which allows to exempt the corporate tax at 95% of the dividends paid to the holder company by their subsidiaries, that is, an almost total exemption.
Another advantage, the benefits of dividend payment are not subject to the Single Fixed Rate Tax (“Fixed Tax”) on capital income, currently 30%, provided that capital gains remain within the Tenderora company, that is, without being distributed to shareholders.
Certain types of holdings can also benefit from the benefits in the transmission of heritage provided by the Dutreil Pact, a dispute system that exempts family businesses to 75%.
Zucman holdings or taxes?
Although the PS requested the implementation of a 2% tax per year in the assets of more than 100 million euros, popularized by economist Gabriel Zucman, the prime minister should offer them another path, whose performance estimated at around 1.5 billion, according to the statements of the head of the Socialists Olivier Faure in order to Matignon.
Did not specify the modalities of the holdings mentioned in this tax; Only certainty: the exemption of professional goods.
Deputy Charles de Courson (Liot) had proposed to establish “a loss of furniture”, a deduction on the income of family holdings not distributed to their shareholders, at a rate that must be discussed, but that can amount to 15%.
According to several media, the Fiscal Administration is working on a lever aimed at “excess effective” of holdings, particularly heritage holdings, excluding professional assets.
The illustration of the tensions surrounding the issue, the General Directorate of Public Finance (DGFIP) did not want to provide details to the AFP regarding the current methods of tax taxes in France.
Source: BFM TV
