Family office in France: holding companies, sociétés civiles and the Pacte Dutreil after the 2026 Finance Law

French law does not regulate family offices as a category. The question is which regulated services are provided and to whom. Discretionary portfolio management for third parties requires authorisation as a portfolio management company (société de gestion de portefeuille) by the AMF under Article L.532-9 of the Monetary and Financial Code; investment advice requires registration as a conseiller en investissements financiers (CIF) with ORIAS and membership of an AMF-approved association under Article L.541-1; arranging insurance contracts or real estate transactions brings in insurance intermediary registration and the real estate professional card. A single-family office serving only its own family group generally relies on the absence of third-party clients and on the intra-group exemption in Article L.531-2. Recital 7 of the AIFM Directive confirms that family investment vehicles not raising external capital are not AIFs. Most French multi-family offices therefore operate as CIFs, often with additional insurance and real estate registrations, while some hold a full AMF management licence.

The structure usually starts with a holding company, commonly an SAS. A holding animatrice that actively steers its subsidiaries is treated as an operating company, which matters for the Pacte Dutreil and for wealth tax. Within the group, the parent-subsidiary regime exempts dividends on holdings of at least 5% held for two years, subject to a 5% add-back, and long-term gains on participations are largely exempt. For portfolios and real estate, French families use the société civile: a tax-transparent civil company whose articles can give parents, as managers, wide powers while children receive shares, often in bare ownership with parents keeping the usufruct. Founders who sell a business frequently contribute shares to a holding first under Article 150-0 B ter, deferring the gain if at least 70% of the proceeds are reinvested in qualifying economic activities within three years, under rules tightened by the 2026 Finance Law.

The Finance Law for 2026 (Law No. 2026-103 of 19 February 2026, published on 20 February 2026) changed the landscape for family holdings. A new Article 235 ter C of the General Tax Code imposes an annual 20% tax on non-operating assets held by patrimonial holdings with assets of at least EUR 5 million that are at least 50% owned or controlled by an individual and his or her family and earn mainly passive income. The targeted assets include yachts, aircraft, passenger vehicles, jewellery and precious metals, racehorses, wine and spirits, hunting and fishing rights, and housing made available free or below market to the family; works of art are not included. The tax applies for financial years ending on or after 31 December 2026, also reaches foreign holdings owned by French residents, is capped by reference to income and has a safeguard clause. The same law excluded such non-operating assets from the Pacte Dutreil and extended the individual holding commitment from four to six years for transfers from 21 February 2026.

Other wealth taxes shape where assets sit. France taxes real estate wealth (IFI) above EUR 1.3 million at rates up to 1.5%; investment income and gains are usually taxed at a flat rate that rose to 31.4% after the 2026 increase in social levies; and the differential contribution on high incomes (CDHR), ensuring an effective minimum of 20% for households above EUR 250,000 (single) or EUR 500,000 (couples), was extended until the public deficit falls below 3% of GDP. Trusts with a French settlor, beneficiary or asset must be registered and can trigger an annual 1.5% tax. New residents may use the impatriate regime of Article 155 B, and non-EU investors can obtain a multi-year talent residence permit by investing at least EUR 300,000 in tangible or intangible assets and creating or safeguarding jobs in France within four years.