For the year 2025, French tax residents with annual income exceeding €250,000 for single taxpayers and €500,000 for married couples or those in a civil partnership will be subject to an effective minimum tax of 20%. This mechanism is designed to ensure that their level of taxation does not fall below this threshold, a situation previously possible mainly due to the 12.8% flat tax on certain gains and income from financial assets. In this article, we will use numerical examples to illustrate how this tax operates and help our readers better understand its overall fiscal impact.

The 2025 Finance Act introduced Article 163 bis H into the French Tax Code (CGI). This new provision establishes a default rule of taxation as employment income for gains realized on securities subscribed, acquired, or granted to employees or company executives, when these gains are earned as compensation for their functions. By exception, a portion of the gain may qualify for capital gains taxation under Article 150-0 A of the CGI, provided it falls within a threshold determined by a statutory formula that considers a performance multiple.

In the coming decades, the world is poised to experience the largest intergenerational transfer of wealth in history. Known as the "Great Wealth Transfer," this unprecedented phenomenon will see substantial assets shift into the hands of younger generations, reshaping economic balances.

France stands out on the international stage with attractive tax and social security regimes designed to encourage the relocation of expatriates—individuals transferring their tax residence to France to live and work there.

When faced with a request for information from the tax authorities, it is crucial to act promptly. Regularization cases can be particularly complex and time-consuming, especially due to the administration's right of reassessment.

The nearly immediate transfer of dividends to its sole shareholder and the lack of significant economic activities by the parent company strongly indicate the absence of beneficial ownership.

The October issue of Ingénierie Patrimoniale (Journal of Wealth Engineering - JFA) features an in-depth article by Sandro Assogna, lawyer and founder of TaxLhab, on Italy's new optional early payment regime for inheritance and gift tax (ISD), effective from 2025 on asset transfers from trusts.

The tax regime for impatriates is a great opportunity for companies in France looking to attract international talent. This system allows impatriate employees and executives to benefit from significant tax exemptions on their income for a maximum period of eight years.

An important decision regarding the application of the Contribution exceptionnelle sur les hauts revenus (CEHR) on French-sourced dividends paid to an Italian resident

Italy offers a favorable tax regime for retirees who decide to transfer their tax residence to the country, aiming to attract investments, stimulate consumption, and bring resources to the southern regions. This regime allows for a substitute tax of 7% on foreign income for a maximum duration of 9 years.

The most significant novelty of the reform is the introduction of an optional regime of advance taxation at the time of the transfer of assets to the trust or the opening of the estate.