By Annick Amigo-Bouyssou, Partner — COTEG Avocats, Toulouse

The 2025 income tax filing season officially opened on 9 April 2026 on impots.gouv.fr. This year brings an upward adjustment to the impôt sur le revenu (personal income tax) brackets, the effective entry into force of the Contribution Différentielle sur les Hauts Revenus (CDHR — minimum tax on high earners), the reintegration of depreciation allowances for non-professional furnished lettings (LMNP), and no change to the IFI (Impôt sur la Fortune Immobilière — Real Estate Wealth Tax). Business owners and real estate investors in particular should pay close attention. Here is an overview of the key points for the 2026 filing campaign.

A Tight Filing Calendar — Deadlines Are Mandatory

The online filing service has been open since 9 April 2026. The filing deadlines vary depending on the taxpayer's département of residence:

• Zone 1 (départements 01 to 19 and non-residents): Thursday, 21 May 2026 at 11:59 p.m.
• Zone 2 (départements 20 to 54, including Corsica): Thursday, 28 May 2026 at 11:59 p.m.
• Zone 3 (départements 55 to 976): Thursday, 4 June 2026 at 11:59 p.m.

Taxpayers who still file on paper — an option now reserved for those without internet access — must submit by Tuesday, 19 May 2026.

Note for taxpayers in Toulouse: Haute-Garonne (département 31) falls within Zone 2, with a deadline of 28 May 2026.

Late filing results in a 10% surcharge on the tax due, which may rise to 40% if a formal notice to file remains unheeded.

Personal Income Tax Brackets: A 0.9% Upward Adjustment

The loi de finances pour 2026 (2026 Finance Act) has adjusted the progressive income tax brackets by 0.9% to partially account for inflation. Tax rates themselves remain unchanged.

Brackets Applicable to 2025 Income (2026 Return)

Taxable income bracket (per part)	Rate
Up to €11,600	0%
From €11,601 to €29,579	11%
From €29,580 to €84,577	30%
From €84,578 to €181,917	41%
Above €181,917	45%

The 0.9% adjustment falls short of actual inflation, meaning taxpayers whose income has merely kept pace with the cost of living may face a slight increase in real tax liability in certain cases. Business owners who draw indexed remuneration should be particularly mindful of this.

The CDHR: A 20% Minimum Tax Rate for High Earners

The major development in this year's filing campaign is the effective application of the Contribution Différentielle sur les Hauts Revenus (CDHR) — a top-up contribution introduced by Article 10 of loi de finances n° 2025-127 of 14 February 2025 (Article 224 of the CGI — Code Général des Impôts).

Who Is Affected?

The CDHR applies to tax households (foyers fiscaux) resident in France whose revenu fiscal de référence (RFR — reference tax income) exceeds:

• €250,000 for single, widowed, separated, or divorced taxpayers;
• €500,000 for taxpayers subject to joint taxation (married couples or civil partners — PACS).

How Does It Work?

The mechanism guarantees a minimum effective tax rate of 20%. The tax authority compares:

1. 20% of the taxpayer's adjusted revenu fiscal de référence;
2. The total actually paid in respect of personal income tax, the contribution exceptionnelle sur les hauts revenus (CEHR — exceptional surtax on high incomes), and withholding tax at source (prélèvements libératoires), plus €1,500 per dependant and €12,500 for taxpayers subject to joint taxation.

If the amount paid falls below the 20% threshold, the shortfall constitutes the CDHR.

An Advance Payment Made in December 2025

Taxpayers concerned were required to pay an advance equal to 95% of the estimated contribution between 1 and 15 December 2025. Any balance owed — or any refund in the event of an overpayment — will be settled upon receipt of the tax assessment notice during summer 2026.

Who Should Review Their Position?

The CDHR primarily targets taxpayers who, by virtue of their income structure (investment income subject to the flat tax PFU at 12.8%, capital gains benefiting from allowances, tax optimisation arrangements), have an effective tax rate below 20%. Business owners who receive a significant proportion of their income as dividends or capital gains on disposals should review their position without delay.

Recommendation: As the CDHR calculation is technically complex, a simulator is available on impots.gouv.fr. Professional tax advice is strongly recommended for taxpayers with complex asset structures.

LMNP: The Reintegration of Depreciation Allowances Changes the Equation

The loi de finances pour 2025 (Article 84 of loi n° 2025-127 of 14 February 2025) introduced a significant change for non-professional furnished lettings (loueurs en meublé non professionnels — LMNP): the reintegration of depreciation allowances into the calculation of the taxable capital gain on disposal.

What Changes in Practice

For any disposal made on or after 15 February 2025, the acquisition price is now reduced by the total depreciation allowances deducted during the letting period (new Article 150 VB III of the CGI). The calculation formula becomes:

> Taxable capital gain = Disposal price – (Adjusted acquisition price – Cumulative depreciation deducted)

A Worked Example

An investor who acquired a property for €200,000 and deducted €50,000 in depreciation over ten years:

• Before the reform: capital gain = disposal price – €200,000
• After the reform: capital gain = disposal price – (€200,000 – €50,000) = disposal price – €150,000

The taxable base mechanically increases by €50,000, subject to personal income tax (19%) and social levies (prélèvements sociaux — 17.2%).

Recent Guidance from the Tax Authority

In a ministerial reply dated 24 March 2026 (Rép. min. n° 10097, Mette), the administration clarified an important point: the reintegration applies to disposals made on or after 15 February 2025, not only to properties acquired after that date. LMNP investors who have held properties for several years are therefore directly affected.

Exceptions: depreciation relating to construction, reconstruction, extension, or improvement works is not reintegrated. Similarly, deferred depreciation allowances (i.e. amounts never actually deducted) fall outside the scope of the measure.

IFI 2026: Confirmed Stability

For taxpayers subject to the Impôt sur la Fortune Immobilière (IFI — Real Estate Wealth Tax), the 2026 campaign holds no major surprises.

Threshold and Brackets Unchanged

The tax threshold remains at €1,300,000 of net taxable real estate assets as at 1 January 2026. The progressive bracket structure is unchanged:

Net taxable estate bracket	Rate
Up to €800,000	0%
From €800,000 to €1,300,000	0.50%
From €1,300,000 to €2,570,000	0.70%
From €2,570,000 to €5,000,000	1%
From €5,000,000 to €10,000,000	1.25%
Above €10,000,000	1.50%

The décote (taper relief) continues to apply for estates between €1,300,000 and €1,400,000 (décote = 17,500 – 1.25 × net taxable estate).

Reminder: IFI Filing Is Integrated Into the Income Tax Return

Since 2018, there is no longer a standalone IFI filing. Liable taxpayers declare their real estate assets as part of their income tax return (form 2042-IFI), subject to the same deadlines.

Key Points for Business Owners

• Professional assets: assets used for professional purposes remain excluded from the IFI tax base. However, the tax authority is increasingly vigilant regarding the reality of such professional use, particularly for SCIs (sociétés civiles immobilières — real estate holding companies) holding mixed-use properties.
• Asset valuation: the market value used must reflect market prices as at 1 January 2026. In a still uncertain real estate environment, a downward revaluation may be justified if supported by substantiated evidence (appraisals, market comparables).
• SCPI and OPCI units: units held in these vehicles (SCPIs — sociétés civiles de placement immobilier, and OPCIs — organismes de placement collectif immobilier, both being real estate investment vehicles) are subject to IFI to the extent they represent real estate assets. Fund management companies publish this fraction annually — it must be carried over carefully.

Practical Tips for the 2026 Filing Campaign

1. Check pre-filled information carefully: an automatically generated return does not remove the need for rigorous verification, particularly regarding rental income (revenus fonciers), investment income (revenus de capitaux mobiliers), and capital gains.

1. Plan ahead for the CDHR: if your RFR exceeds the relevant threshold, reconcile the advance payment made in December 2025 with your actual tax position.

1. Reassess your LMNP strategy: the reintegration of depreciation allowances makes it essential to reconsider the timing of disposals of furnished rental properties. A wealth review may prove worthwhile before any decision to sell.

1. Update your IFI asset values: take market developments into account when valuing your assets as at 1 January 2026.

1. Do not wait: the deadlines are short. For complex cases, contact your adviser now.

COTEG Avocats assists business owners, investors, and private clients with all aspects of their tax affairs. For any question relating to your 2026 return, please do not hesitate to contact us.

Annick Amigo-Bouyssou — Partner, specialist in corporate law and tax law. Member of the Municipal Council of the City of Toulouse, with responsibility for public safety and public procurement.

COTEG Avocats — Toulouse