France Holding Company 2025 | 95% Dividend Exemption, Niche Copé

The French Holding Regime

France offers a competitive holding regime at the heart of the European Union. The régime mère-fille (participation exemption) and niche Copé (capital gains exemption) make France attractive for group structures and M&A operations.

Participation Exemption: Dividend Taxation

The régime mère-fille allows 95% exemption on dividends received from subsidiaries (5% taxed as management expense add-back). Conditions:

• Participation threshold: 5% minimum of share capital
• Holding period: 2-year holding commitment
• Taxation condition: Subsidiary must be subject to corporate tax or equivalent
• Legal form: Participating company must be subject to corporate tax

Effective tax rate on dividends: only ~1.25% (5% × 25% corporate tax rate).

Capital Gains: Niche Copé

Capital gains on qualifying participations (titres de participation) benefit from 88% exemption - only 12% is taxed (quote-part de frais et charges).

• Qualifying participations: 5% minimum holding for at least 2 years
• Effective tax rate: ~3% (12% × 25% corporate rate)
• Portfolio securities: Full taxation at 25% corporate rate

Fiscal Integration

The intégration fiscale regime allows parent companies holding 95%+ of subsidiaries to file a consolidated tax return:

• Result consolidation: Offset profits and losses within the group
• Neutralization: Intra-group transactions neutralized
• Single return: Parent company files for the entire group
• 5-year commitment: Option is irrevocable for 5 years

Tax Treaty Network

France has concluded over 120 tax treaties, one of the world's most extensive networks. Benefits include:

• Reduced withholding taxes on dividends, interest, royalties
• Elimination of double taxation
• Parent-Subsidiary Directive: 0% withholding on dividends to EU parents
• Interest and Royalties Directive: 0% withholding on qualifying payments

Why France for Holdings?

Aspect	French Regime
Dividend exemption	95% (effective rate ~1.25%)
Capital gains exemption	88% (effective rate ~3%)
Tax consolidation	Available (95% ownership)
Tax treaties	120+ countries
EU Directives	Full implementation
IP regime	IP box ~10% rate

Holding Structures

• SAS (Simplified Joint-Stock Company): Most flexible, popular for holdings
• SA (Public Limited Company): For larger groups, allows stock listing
• SARL: Simpler structure for family holdings
• SCA (Partnership Limited by Shares): Combines management control with capital flexibility