Tax breaks for high earners: strategies and optimization in the era of the CDHR
For households where the reference tax income (RFR) Once income crosses significant thresholds (often exceeding €250,000 for a single person and €500,000 for a couple), the tax burden in France is no longer limited to the simple progressive income tax scale. In 2025 and 2026, the legislative accumulation—between the Exceptional contribution on high incomes (CEHR) and the news differential contribution on high incomes (CDHR) — transforms tax optimization into a veritable high-wire act.
The challenge for these taxpayers is no longer simply to "pay less tax", but to manage their finances intelligently. minimum tax rate to avoid tax catch-up mechanisms while building resilient wealth. This comprehensive guide deciphers the strategies of tax breaks for high incomes the most effective in this new paradigm.
1. The New Tax Landscape: Understanding the CDHR and the CEHR
The current budgetary framework, characterized by the 2026 Finance Law, introduced a complex variable: the State's willingness to establish an effective tax floor.
The Differential Contribution on High Incomes (CDHR)
There CDHR is a catch-up mechanism. If your effective tax (after deductions and credits) falls below a certain threshold — set at 20 % income included in the calculation — an additional tax fills the gap.
The strategic impact: This means that multiplying classic "tax loopholes" can become counterproductive if they push you below the 20 % threshold. Optimization should now focus on the tax deductions which lower the RFR upstream, rather than solely on downstream tax reductions.
The Differential Contribution on High Incomes (CDHR)
There CDHR is a catch-up mechanism. If your effective tax (after deductions and credits) falls below a certain threshold — set at 20 % income included in the calculation — an additional tax fills the gap.
The strategic impact: This means that multiplying classic "tax loopholes" can become counterproductive if they push you below the 20 % threshold. Optimization should now focus on the tax deductions which lower the RFR upstream, rather than solely on downstream tax reductions.
The Exceptional Contribution (CEHR)
Still in effect, the exceptional contribution on high incomes It adds a layer of 3 to 4 % beyond certain thresholds. Combined with the marginal tax rate (MTR) of 45 %, the marginal tax can approach 50 %, not including social security contributions.
2. Deduction Strategies: Acting on the Reference Tax Income (RTI)
For the high-income taxpayers, The absolute priority is to reduce the tax base even before the tax is calculated. This is where the mechanisms of'tax optimization The most powerful ones enter the fray.
The Retirement Savings Plan (PER): The essential tool
The PER allows you to deduct the payments made from your total income, up to a limit of 10 % of your professional income (with a generous ceiling for the self-employed).
The appeal for high incomes: If you are in a tax bracket of 45% (%), a payment of €30,000 generates a income tax reduction indirect of €13,500. Most importantly, this payment lowers your RFR, which is crucial to mitigating the impact of the CDHR.
Land Deficit: Moving Beyond the Cap on Tax Breaks
Unlike many tax advantages, the land deficit is not subject to capping of tax loopholes of €10,000.
The mechanism: By carrying out renovation work on a rental property (excluding extensions), you can deduct all expenses from your rental income, up to €10,700 (or even more in certain specific schemes like the Denormandie scheme) from your overall income. This is a tool for wealth management strategy of formidable effectiveness for owners of large real estate portfolios.
3. One-Shot Tax Reductions: Immediate Cash Flow Lever
Once income is optimized, it is possible to influence the amount of tax owed through targeted mechanisms, often linked to the economic development of territories or businesses.
The Girardin Industrial Law: Pure Tax Return
L''Girardin investment industrial financing involves financing industrial equipment for companies located in the DOM-COM. In return, the investor benefits from a immediate tax reduction the following year, higher than his initial investment (the "gain" is generally between 10 % and 15 %).
Balmont's Eye: It's a tool for tax profitability pure. However, the tax risks are real if the overseas company does not comply with the operating conditions for 5 years. Expert support is available to verify the non-conformity clauses is indispensable here.
Private Equity and FIP/FCPI funds
Investing in unlisted SMEs allows you to obtain a tax reduction (often 18% or 25% depending on the legislation in effect at the time). Beyond the tax advantage, it's an excellent way to diversify your assets in the real economy, although it requires a high risk tolerance and a long-term investment horizon.
4. High-Balance Sheet Real Estate Tax Optimization
For households in high incomes, Traditional schemes like the Pinel scheme are often insufficient because they have excessively high caps. It is therefore necessary to turn to more structural solutions.
The Malraux Law and the Historic Monument
These measures are specifically aimed at taxpayers with a very heavy tax burden.
- Malraux: Tax reduction of 22 % or 30 % of the amount of work for the complete restoration of a building located in a protected area.
- Historical Monument: This is the "holy grail" of tax optimization. All renovation work and condominium fees are deductible from total income, without any limit. It's the most powerful mechanism for eliminating a exceptional contribution or a TMI at 45 %.
LMNP (Non-Professional Furnished Rental)
While the LMNP (furnished rental property) is not a "tax relief" scheme in the sense of a tax reduction, it is a tool for wealth management This is an excellent way to generate future income. Thanks to accounting depreciation, rents received are not taxed for decades, thus avoiding further burdening an already high taxable income.
5. Case Study: The Couple of Independent Surgeons
Situation :
A couple of self-employed surgeons report a non-commercial profit (BNC) of 350 000 €. They are taxed at a marginal tax rate of 45 % and are directly impacted by the additional contribution on high incomes.
The problem :
Their taxation is perceived as confiscatory (more than €120,000 in annual taxes), which hinders their ability to save for a retirement that will see their income fall drastically.
The Balmont Consulting Strategy:
- Action on the RFR: Payment of €35,000 each to a PER. Immediate tax savings: 31 500 €.
- Action on tax loopholes: Subscription to Girardin Industriel with an investment of €40,000, generating a tax reduction of €45,000 the following year.
- Structural action: Acquisition of real estate under the regime of land deficit with €50,000 of planned work.
CDHR Prevention: Tax simulation specifies to ensure that all the schemes do not cause their average tax to fall below the threshold of 20 %, which would render some of the efforts useless.
Expected result:
An overall tax saving estimated at more than 50 000 € per year, a significant decrease in reference tax income and the creation of a quality real estate asset entirely financed by tax savings and rents.
Limits and Vigilance: The Role of Professional Advice
L''tax optimization Managing high incomes requires careful planning and attention to detail. Several safeguards must be in place:
- The Capping of Tax Loopholes: Limited to €10,000 per year (with extensions to €18,000 for Girardin and SOFICA schemes). Staying within this limit is the foundation of any investment strategy. wealth management strategy.
- Abuse of Rights: The tax authorities can reclassify a transaction whose sole purpose is to evade taxes. Every investment must have its own economic rationale.
- The Quotient Method: In the case of exceptional income (business sale, compensation), the use of the quotient method makes it possible to smooth out taxation and avoid a jump into a higher tax bracket too abruptly.
Should you be accompanied?
The answer is yes. High-income households are a priority target for the administration. Hiring a firm like Balmont Conseil allows not only to maximize the income tax reduction, but also to secure the annual income tax return and to ensure the tax compliance selected media. In 2026, with the complexity of the CDHR, The cost of a calculation error is far greater than the fees of an expert advisor.
7. Summary Table: Tax Relief Levers 2026
Device | Type of benefit | Capping | Risk |
PER | Deduction from total income | 10 % of professional income | Weak |
Land deficit | Deduction of rental income | Outside the ceiling of the niches | Moderate (works) |
Girardin Industriel | One-shot tax reduction | 18 000 € | Raised (farm) |
Malraux | Tax reduction | Beyond the ceiling (subject to conditions) | Moderate |
Historical Monuments. | Total deduction | None | Low (but high cost) |
LMNP | Untaxed income | N / A | Weak |
Balmont's perspective: Anticipation is your best asset
In wealth management, time is a multiplier for tax performance. Waiting until December to "look for tax breaks" guarantees you'll end up with mediocre products. A real revenue optimization begins as early as January, with a tax simulation based on your projected income.
