France reforms taxation on investment income and wealth

01.12.17
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Please note that this article is over six months old. While Blevins Franks takes care to make sure that information is accurate on the date of publication, some content may change over time. You should not rely on the accuracy of legislation and tax information in this article; take professional advice for your circumstances.

From 2018 French residents no longer have to pay wealth tax on savings and investments, and investment income benefits from a new tax rate.

From 2018 French residents no longer need to pay wealth tax on savings and investments, and investment income benefits from a new tax rate.

There have been a number of tax reforms in France over recent years; reforms that usually led to higher taxes. So it makes a refreshing change to be able to write about tax cuts this time. For general income (employment, pensions etc) taxation will remain pretty much the same as this year, but 2018 will see significant changes to how investment income and wealth are taxed.

President Macron released his first budget at the end of September, which followed up on the tax promises made in his electoral campaign. As always in France, the budget takes a few months to be debated and pass through parliament. In fact, the Constitution states that 70 days have to elapse between the budget being proposed and approved. So nothing is certain until it is approved towards the end of the year, though we do not expect major changes to the reforms outlined below.

Wealth tax

Wealth tax – Impôt de solidarité sur la fortune (ISF) – was introduced in 1982 by President Mitterrand. It has been unpopular among France’s wealthier families ever since, causing some to leave the country to avoid it. President Nicolas Sarkozy had made an effort to reduce the tax burden, but this was soon overturned by President Hollande.

Under current rules, you are liable to wealth tax if you are resident in France on 1st January and the taxable wealth of your household amounts to over €1,300,000. It is based on worldwide assets, from property and investments to jewellery and cars. The first €800,000 is exempt from this tax, with rates then rising from 0.5% to 1.5%. Non-residents are liable on assets they own in France. It is paid by around 350,000 households and earned the government €5 billion in 2016.

Under the reforms, from 1st January 2018 this form of wealth tax will be replaced by l’impôt sur la fortune immobilière or “IFI”. This is still a ‘wealth tax’, but the plan is that it will now only apply to real estate.

Importantly, savings and investments will be excluded from the new wealth tax. So whether your investment portfolio is €100,000, €1,000,000 or €10,000,000, it will no longer be liable for wealth tax. This includes assurance-vie policies.

The thresholds, tax rates, time periods, payment etc remain the same for the new wealth tax as for the current version. Main homes will continue to benefit from the 30% abatement and the 75% limit will also still apply.

It is calculated that this reform will cost the government €3.2 billion in tax revenue.

Flat 30% rate on investment income

One of the key reforms of President Hollande’s government was to remove the fixed rates of tax for investment income – interest, dividends, capital gains on the sale of securities etc – and to start to tax it at the scale rates of income tax. For higher earners, this meant higher tax bills. Income tax rates go to up 45%, plus another 4% for income over €500,000, plus social charges of 15.5%.

The 2018 budget will reinstate a fixed rate of tax for investment income, and a lower one than we had before.

If it all goes ahead as planned, unearned income (so income from investment assets) will be taxed at one fixed rate of 30%. And while normally you have to add social charges on top, in this case the 30% includes social charges – so the income tax part is just 12.8%.

Lower earners will not pay more tax under this system, as the fixed rate will only apply to assurance-vie and other investment policies over €150,000 (€300,000 for a joint policy). Those with lower policies will continue to pay the scale rates of income tax.

This 30% tax rate and rules will also apply to assurance-vie policies set up after 26th September 2017 (though the fixed rate will not start being applied till January).

If you already have an assurance-vie policy, then you can still use the old fixed rate system, and can still opt for the scale rates of income tax if that works out better for you.

Whether you have an old or new assurance-vie policy, taxation continues to only apply to withdrawals, and only to the gain element of withdrawals (provided you have an approved policy). Income and growth will continue to roll up tax-free. Policies held for more than eight years will also continue to benefit from the €4,600 prélévement libératoire allowance (€9,200 for married couples/PACS partners).

All the succession planning benefits of assurance-vie policies continue to apply; there no proposed changes here.

Social charges

Social charges are made up of five elements, and the contribution sociale généralisée (CSG) part increases by 1.7% from January. This mean that in 2018 social charges will be 9.7% on employment and self-employment income; 9.1% in pension income and 17.2% on investment income (including rental income).

Remember, however, that you do not need to pay social charges on pension income if you do not yet have access to the French health system or have EU Form S1.

Note that these reforms still need to be finalised, and we also still need full clarification of how they will work.

Overall this budget is good news for expatriates who have investment wealth. The combination of the new flat rate on income and not having to pay wealth tax could make a considerable difference to how much tax you pay next year. Talk to Blevins Franks to make sure you understand how the new rules will affect you and your wealth is set up to take full advantage of the reforms.

The tax rates, scope and reliefs may change. Any statements concerning taxation are based upon our understanding of current taxation laws and practices which are subject to change. Tax information has been summarised; an individual is advised to seek personalised advice.

Tax rates, scope and reliefs may change. Any statements concerning taxation are based upon our understanding of current taxation laws and practices which are subject to change. Tax information has been summarised; individuals should seek personalised advice.