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France’s Top Auditor Urges Overhaul of Pacte Dutreil After €5.5 Billion 2024 Cost

The finance ministry signaled it wants the tax break preserved with limited tweaks.

Overview

  • The Cour des comptes published a report estimating the Pacte Dutreil deprived the state of more than €5.5 billion in 2024 and said its economic benefits are not clearly observed.
  • Its recommendations include excluding non‑professional assets, curbing optimisation schemes, lowering the 75% exemption, lengthening holding requirements, and introducing progressive or exposure‑based relief, which it says would more than halve the fiscal cost.
  • Bercy praised the analysis but argued for adjustments rather than a rewrite, floated an explicit list of somptuary assets to exclude, and questioned the Court’s calculations.
  • Lawmakers have already moved to tighten the regime, with deputies voting on November 3 to remove non‑professional assets from the exemption as the budget heads to the Senate from November 24.
  • Business groups including Medef and Meti condemned the report as unbalanced, while the Court highlighted that about two‑thirds of the advantage goes to the top 1% of heirs and noted years of official underestimation of the measure’s cost.