Newsletter March 2026

​New decree: hiring incentives for apprentices clarified for 2026

Published in the Official Journal on March 7, 2026, Decree No. 2026-168 of March 6 introduces an exceptional support scheme for employers hiring apprentices for contracts concluded from March 8 and starting before January 1, 2027. This text implements the announcements made in the Finance Act and the Social Security Financing Act by setting amounts that vary depending on the level of qualification and the size of the company.

For companies with fewer than 250 employees, the single support payment remains €5,000 for qualifications up to baccalaureate level (levels 3–4). For higher education programs, the maximum amount is €4,500 for level 5 (bac+2, BTS/DUT) and €2,000 for levels 6–7 (bachelor’s degree, master’s degree, engineering degree). The amount may be increased to €6,000 for apprentices with disabilities. The aid is paid only during the first year and is managed by the ASP via the DSN system.

Finance Act for 2026: measures affecting entrepreneurs

Tightening of the contribution-sale mechanism in 2026 

The contribution-sale mechanism allows an entrepreneur to sell company shares without immediately paying tax on the capital gain. How does it work? You transfer your shares to a holding company (a company subject to corporate tax) that you control. The latent capital gain is placed under a tax deferral regime (not cancelled, only deferred).

Then, if the holding company sells these shares within three years after the contribution, the tax deferral is maintained as long as part of the sale proceeds is reinvested in productive economic activities (industry, trade, crafts, agriculture, or liberal professions – excluding purely asset management activities and real estate activities such as property development or property trading).

Major changes introduced by the 2026 Finance Act (applicable to disposals carried out from February 21, 2026):

• The minimum percentage to be reinvested increases from 60% to 70% of the sale proceeds. Example: for a €1 million sale, at least €700,000 must be reinvested (instead of €600,000 previously).
  • The deadline for completing this reinvestment is extended from 2 years to 3 years (a compensatory flexibility measure).
• The assets or shares acquired through this reinvestment must be held for 5 years (instead of 1 year previously), in order to encourage longer-term commitments.
• Eligible activities are now more strictly defined: purely asset-based or real estate investments (development, rental activities, etc.) are excluded, even when carried out through certain funds.

If these conditions are not met (insufficient reinvestment, disposal of the contributed shares, etc.), the deferral ends and the capital gain becomes taxable under the flat tax regime (31,4%, including income tax and social contributions), possibly with the additional contribution on high incomes.

New tax on asset-holding companies

The Finance Act introduces a new tax targeting asset-holding companies: an annual tax of 20% on the market value of certain non-professional luxury assets held by these structures. Codified under Article 235 ter C of the French Tax Code, it applies to financial years closing from December 31, 2026 (first taxation relating to 2026, declared in 2027).

Initially proposed at 2% on a broad tax base (including cash and financial assets), the measure was narrowed through parliamentary amendments (notably the “Juvin” amendment) to focus on leisure or luxury assets. The measure is expected to generate modest budget revenue estimated at around €100 million, but with a strong deterrent effect.

Who is concerned? Companies (French or foreign companies controlled by French tax residents) subject to corporate income tax, which cumulatively meet the following criteria:

• Total asset value ≥ €5 million (valued at market value)
• Control by one or more individuals (≥ 50% of voting rights or effective decision-making power)
• Companies receiving more than 50% of their income from passive sources (dividends, interest, rents, etc.)

Taxed assets (exhaustive list):

• Non-professional passenger vehicles (including collector vehicles)
• Yachts and pleasure boats
• Aircraft not operated commercially
• Private-use residential properties (secondary residences or prestige properties reserved for personal or family use free of charge or at a reduced cost)
• Jewellery and precious metals
• Race or competition horses
• Assets related to non-professional hunting or fishing
• Collectible wines and spirits

Excluded assets include cash, financial securities, works of art (with certain exceptions) and genuine business assets.

Practical arrangements for declaration and payment

The tax is calculated on the gross market value of the relevant assets at the financial year-end (deductions are limited to debts directly linked to the assets, similar to the rules applied to real estate). It is not deductible from corporate income tax and is intended to discourage the holding of luxury assets through a company in order to circumvent the French real estate wealth tax (IFI). Real estate assets subject to this tax are exempt from IFI to avoid double taxation.

• For French holding companies: the company itself is liable. The tax is declared as an annex to the corporate tax return (specific form detailing the tax base), in accordance with corporate tax rules.
• For foreign holding companies controlled by individuals who are French tax residents: the individual (or individuals concerned, proportionally) is directly liable. The tax is declared in the annual income tax return (form 2042 or a dedicated annex), indicating the value of the relevant assets, the direct or indirect ownership percentages and the value of the shares. Payment is made together with the balance of income tax (generally in September or October of year N+1).

Mandatory electronic invoicing: stricter penalties, do not delay

The reform of electronic invoicing is approaching rapidly, and the Finance Act for 2026 significantly strengthens penalties to encourage compliance.

From September 1, 2026, all businesses (including self-employed professionals and very small companies) must be able to receive electronic invoices via an approved platform. Failure to comply with this obligation, after a formal notice period of three months, may result in a €500 fine, renewable up to €1,000 per period if the non-compliance continues.

For the issuance of invoices (which will become mandatory for SMEs and very small businesses on September 1, 2027), the penalty for a non-compliant invoice increases from €15 to €50 per invoice, capped at €15,000 per year.

E-reporting (the transmission of transaction data) is also affected, with penalties doubled to €500 per breach.

These more dissuasive amounts highlight the urgency: do not let the reform catch you unprepared.

Start preparing now by selecting and registering with an approved platform to ensure that you are ready to receive (and soon issue) your electronic invoices from September 1, 2026.