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Dutreil pact
Dutreil pact: pass on your business and pay tax on only a quarter of its value.
The signatories commit to retaining the shares, one of them continues to manage the company, and gift or inheritance taxes are now limited to 25% of the value. The 2026 Finance Act extended the heirs' commitment period: here are the rules that now apply.
of the value of the securities or the company exempt from gift and inheritance taxes (article 787 B of the CGI).
additional reduction on the taxes of a gift in full ownership made before age 70 (article 790 of the CGI).
to pay the remaining duties: 5 years deferral, then 10 years of payment in installments (article 397 A of appendix III of the CGI).
Worked example
A company worth €4 million, two children, a 65-year-old parent.
Without a pact
A company worth €4 million passed on to two children: €2 million per child, i.e. €1.9 million taxable after the €100,000 allowance.
With a pact
Only 25 % of the value are retained: €500,000 per child, of which €400,000 is taxable.
Result
The agreement is signed before the gift. The remaining taxes are payable over 15 years if necessary.
The pact's constraints
Four conditions.
What changed in 2026
The Finance Act of 19 February 2026.
Frequently asked questions
What we are being asked to do.
Gift or inheritance: when should you use the pact?
During your lifetime, if possible: a gift in full ownership before age 70 adds 50 % of reduction to the 75 % of exemption (article 790 of the CGI), and you choose the time, the value and the sharing between the children.
Can the pact be signed after a death?
Yes: the heirs can enter into a joint commitment among themselves within 6 months of the death (Article 787 B of the French General Tax Code), provided that one of them takes over the management. This is a backup solution, without the 50% tax reduction reserved for gifts.
What happens if an heir sells before the end of their commitment?
The exemption is revoked for him alone, with late payment interest of 0.20 per % per month (Article 1727 of the French General Tax Code). The other heirs retain their benefit. The page on the constraints of the agreement details each case.
Does the agreement apply to a holding company?
A holding company that actively manages its subsidiaries is eligible, according to the conditions of Article 787 B of the French General Tax Code (CGI). A holding company that merely holds shares or investments is not eligible: this is one of the first points checked.
