The finance bill for 2025 has sparked lively debate, and reveals tensions around taxation applied to the highest incomes in France. At the heart of the controversy, an amendment which aims to exempt certain categories of income from the new “differential contribution on high incomes” (CDHR), introduced to limit tax exemption practices among the wealthiest taxpayers. This amendment, intended to maintain attractive taxation for investors in innovation, was rejected by the National Assembly, which constitutes a defeat for the government and a victory for the opposition which is campaigning for an expansion of this contribution.
Rejection of the exemption for industrial and intellectual income
Amendment No. I-3643, proposed by the government as part of the finance bill, aimed to exclude certain categories of income from the differential contribution on high incomes (CDHR). This income included in particular that derived from the “transfer, concession, or sub-concession of industrial property assets”, which already benefit from a specific tax regime with a reduced rate of 10%. In its defense of this amendment, the government specified that this exemption was intended to “preserve the tax attractiveness of income linked to innovation”. It thus hopes to encourage investments in industrial and intellectual property, strategic sectors for France's competitiveness.
In addition, the amendment also targeted income received by individual inventors or their beneficiaries for the transfer or granting of operating licenses for protected software or patentable inventions. The government argued that these revenues, already governed by advantageous tax rules, should be supported in order to encourage innovation and research. However, despite the arguments put forward, this attempt to reduce the tax burden for these wealthy taxpayers was ultimately rejected by the National Assembly on October 22, 2024, which sparked mixed reactions.
Towards a more extensive and sustainable contribution for high incomes
The rejection of amendment No. I-3643 takes place in a context of tougher taxation for higher incomes, with the adoption by the Assembly of two other amendments. Indeed, the first, supported by left-wing groups, aims to perpetuate the differential contribution on high incomes, initially thought to be exceptional, with its extension to more wealthy households. This strategic choice would make it possible to strengthen the State's tax revenues, but also to reduce the differences in treatment in terms of tax exemption among the wealthiest taxpayers.
Furthermore, an amendment defended by the centrist deputy Charles de Courson aims to limit the possibility of recourse to tax loopholes and tax credits, often used to considerably reduce the amount of the differential contribution. This additional measure aims to cap the tax advantages available to wealthy households, which thus increases their net contribution. While the government plans to use article 49-3 to pass the finance bill, the rejection of amendment No. I-3643 and the adoption of these other measures signal a shift towards reinforced taxation. for the wealthiest.
The outcome of this parliamentary debate outlines an increasingly strict tax trajectory for high incomes in France, and aims to limit the use of optimization mechanisms. As the government suffers a setback in its attempt to protect certain innovation revenues, the new measures could reshape the tax landscape and prompt investors to rethink their strategies. It remains to be seen whether this orientation, which will undoubtedly have economic repercussions, will allow France to reconcile competitiveness and fiscal justice, with a view to reducing its deficit.
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