Before the emergency legislation.
When a State has to reassure its creditors, the law that helps it do so is written in a few weeks and applies without delay. The European debt crises bear witness to this. What is decided before the text is still decided freely; what waits for the text is subject to it. The firm offers to draw the consequences, estate by estate, business by business.
The debt thermometer
+1.4pts
This is what France pays, over and above the German rate, to borrow over ten years.
When this spread widens, it is market confidence that is withdrawing. European crises have most often announced themselves this way: in Italy, the decree-law of December 2011 followed the surge in rates by a few weeks. The firm sets an alert threshold at 1.5 points, should it become lasting. Ten-year OAT-Bund spread, closing levels in early October 2026, according to the financial press.
Position as at 12 October 2026. Sources: 2027 Finance Bill (PLF 2027), opinion of the High Council of Public Finance, Agence France Trésor, financial press.
The findings.Eight precedents, one common pattern.
Since 1990, at least eight European countries have experienced a severe public finance crisis: Sweden and Finland at the start of the 1990s, then Ireland, Greece, Portugal, Spain, Italy and Cyprus between 2010 and 2015. In the episodes closest to the French situation, the decisive measures were adopted within a few weeks, by decree-law, amending finance act or memorandum.
They struck wealth, savings and businesses in a single movement, at the same time as pensions and VAT. The temporary became permanent. Targeted measures were sometimes struck down, but often only to the benefit of those who had challenged them.
Under way or imminent
- Extension of the “exceptional” contributions on high incomes and large companiesSpain, Portugal, Italy, Sweden
- Under-indexation of pensions, benefits and tax bracketsIn all eight countries
- Heavier levies on investment income, extending to life insurance and rental incomeItaly: from 12.5% to 26%
- Trimming of preferential regimes: LMNP, Dutreil, life insurance, contribution and sale (apport-cession)Portugal, Ireland, Spain
- For businesses: reduced deductions, earlier tax instalments, deferred public paymentsSpain, Italy
To watch
- Tougher rules on wealth transfer: rates, allowances, look-back on prior giftsIreland; France, 2012
- Higher taxation of let property and second homesSeven precedents out of eight
- Return of a wealth tax or exceptional contribution on assetsSpain, 2011; depends on the presidential election
- VAT increaseLikely only in the event of a rate shock
Extreme scenario
- Levy on deposits, restrictions on withdrawals, freezing of life insuranceCyprus 2013, Greece 2015: only where the banking system was collapsing
View the detailed table of precedents
| Measure | Likelihood in France | Precedents | Who is affected |
|---|---|---|---|
| Extension and increase of contributions on high incomes and large companies | Very highalready under way | Spain, Portugal, Italy; Sweden | Executives, mid-sized companies |
| Under-indexation of pensions, benefits and tax brackets | Very high | All eight countries | Executives nearing retirement |
| Higher levies on investment income, extended to life insurance and rental income | High | Italy (12.5% → 26%), Spain, Portugal, Ireland, Cyprus | Families, savers, property investors |
| Trimming of wealth-related tax reliefs: LMNP, Dutreil, life insurance on death, contribution and sale (apport-cession) | High | Portugal, Ireland, Spain | Executives, families |
| Reduced corporate tax deductions, minimum instalments, public payment arrears | High | Spain; Italy and Spain (arrears) | Businesses, public sector suppliers |
| Tougher rules on wealth transfer: rates, allowances, look-back on prior gifts | Moderate | Ireland; France 2012 | Families |
| Heavier taxation on holding real estate | Moderatehigh in the event of a bond market shock | Italy, Portugal, Ireland, Greece, Spain, Cyprus | Property investors |
| Wealth tax or exceptional contribution on assets | Moderatelinked to the presidential election | Spain 2011; France 2012 | Families, executives |
| VAT increase or shift of reduced rates | Lowhigh in the event of a bond market shock | Six countries out of eight; France 1995 and 2014 | Retail, restaurants |
| Levy on savings, forced loan, freezing of life insurance | Lowextreme scenario | Cyprus; France 1983 | Savers |
The likelihood reflects the firm's assessment; it is not a calculated probability.
The temporary lasts
Introduced in 1995 for a few years, the Swedish surtax on high incomes only disappeared in 2020. A so-called temporary regime should be treated as if it were in place for ten years.
The main residence is the best protected
Let properties and second homes remain the lasting target. Selling one's main residence for fear of taxation would, in light of the precedents, be a misjudgment.
Early challenges pay off
In Spain, the annulment of the minimum corporate tax instalment benefited only those companies that had challenged it in time.
How we support you.In two stages.
First measure the exposure; then act only if the situation calls for it.
First stage · complimentary
The pre-audit.
A meeting with one of the partners and an initial review of your situation: assets, holding structures, transfers under way, business. You leave with a clear answer. Are you exposed, on which items, and is there anything worth doing before 31 December?
Request a pre-auditSecond stage · under a fee agreement
The engagement.
Where the situation calls for a lawyer's involvement, the firm sends you a proposal, together with a fee agreement. The engagement then comprises the stress test described below, the signing of the selected deeds and follow-up until summer 2027. Where nothing justifies it, we tell you so.
Second stage · the diagnosis
A regulatory and wealth stress test.
The diagnosis measures what each possible trajectory would cost an estate or a business, and sets the list of deeds to be signed before 31 December 2026. It is delivered within four weeks.
- 01
Mapping the exposure
Assets, holding structures, income, transfers under way, debt and banking relationships.
Exposure sheet, item by item - 02
Costing three scenarios
The status quo; a slow consolidation, made up of cuts and extensions; an emergency plan extending levies to life insurance, real estate and wealth transfer.
Annual cost and transfer cost - 03
Testing vulnerable positions
Substance of holding companies, contribution and sale (apport-cession), Dutreil undertakings, LMNP, transfer pricing, tax credits, beneficiary clauses.
Points to document or regularise - 04
Signing without delay
Gifts that are ready, splitting of ownership, 2026-2027 remuneration, allocation of cash, wills and powers of attorney.
Signing schedule before 31 December - 05
Preserving rights
Taxes open to challenge through a priority question of constitutionality (QPC) or under EU law; deadlines for claims (art. R.* 196-1 LPF).
Protective claims ready for filing - 06
Preparing without triggering
Early distributions, accelerated gifts, arbitrage of exposed assets, relocation with the exit tax already costed.
Files ready for signature within 48 hours
Act on what holds true in every scenario; prepare the rest without triggering it.
No transaction is proposed for tax reasons alone. Each deed must have its own family or economic rationale, a condition of its validity with regard to abuse of law (Articles L. 64 and L. 64 A of the LPF). The diagnosis is set out in a single document, delivered to the client and, if the client so wishes, to their chartered accountant, notary or wealth management adviser.
Follow-up · until summer 2027
Deciding in hours, not weeks.
Moody's review, the 2027 Finance Act, a possible amending finance act, the presidential election: the firm tracks the signals in the order in which they spread, from the budget to the bond market, from the banks to the political scene, then to real estate. With the deeds already prepared, the decision rests with you alone.
Situation note
The month's events, read in light of the precedents, and the updated likelihood of each measure.
Alert
Downgrade, pressure on rates, announcement of an amending finance act or a crisis government.
Immediate reading
The quantified effect of the adopted law on your situation, and the decision it calls for.
Implementation
Signing of the deeds held ready; filing of claims within the deadlines.
Protective litigation
New targeted contributions, tax bases disconnected from market values, QPC, EU law.
Post-election review
A full update: wealth, transfer and capital taxation will depend directly on the outcome of the vote.
For whom.Two exposures, two forms of preparation.
Executives and families
They are exposed through three channels: investment income, on which the flat-rate levy already reaches 31.4%; preferential regimes, amended or under threat; and finally wealth transfer, a quick lever and rarely challenged where it has been used.
- To start now
- 2026-2027 remuneration decided under three scenarios; gifts that are ready, signed before 31 December under the current allowances (€100,000 per parent and per child); review of beneficiary clauses, wills and lasting powers of attorney (mandats de protection future).
- To prepare without triggering
- Early distributions; accelerating gifts already decided, should an amending finance act be announced; planning any relocation in advance, exit tax included.
- To avoid
- Transactions with a mainly tax-driven purpose. Giving too much, or too early: a gift is irrevocable, a tax scale is not.
Companies and mid-sized businesses
The crisis reaches the balance sheet through four channels: corporate taxation, credit, receivables from public bodies and tax audits. Contracts and shareholdings feel the effects.
- To start now
- Collect tax credits and refunds before any cuts; diversify financing and favour fixed rates; secure public receivables; review indexation and hardship clauses, as well as shareholders' agreements.
- To prepare without triggering
- A cash flow plan that factors in the closure of short-term credit lines; acquisitions of assets at depressed valuations, financed from the reserve built up.
- If cash flow tightens
- Ad hoc mandate (mandat ad hoc) and conciliation, to be opened early, while there is still room for negotiation.
Real estate and cash
A dedicated module tests each rental property against an additional holding cost of 0.5% per year, reviews the holding structure in light of the resale horizon and the allocation of deposits above €100,000 per institution. The firm advises against precautionary mass surrenders of life insurance policies, as it does against selling the main residence. These matters are examined on an ancillary basis to the legal and tax engagement, in liaison with the client's wealth management adviser.
Three dates.Why now.
The 2027 Finance Bill already affects certain transactions carried out since 1st October 2026. Its other measures will probably come into force on 1st January, with nothing to guarantee that none will apply earlier.
23 Oct. 2026
Moody's review
The outlook is already negative; a downgrade would further increase the cost of government borrowing.
31 Dec. 2026
Last useful date, in all likelihood
To sign deeds and file claims under the current regime.
2 May 2027
Presidential election
The vote will determine the fate of the taxation of wealth, wealth transfer and capital.
Analyses.Four readings of the precedents.
The partners.Those who will meet you.
The pre-audit
Complimentary and without obligation. It provides an overview of your position; it does not amount to a recommendation of any transaction.
The engagement
The firm does not bill by the hour. The diagnosis is charged at a fixed fee, depending on the number of structures and assets; the follow-up, at a periodic fixed fee. Deeds are paid for on signature, and protective litigation includes a success fee component. A fee agreement sets out all of this before any work begins.
The scope
Legal and tax advice, and its implementation, in liaison with the client's chartered accountant, notary and wealth management adviser. The firm does not provide investment advice.
Start with a pre-audit.
One meeting is enough to know whether your situation calls for a decision before 31 December. If nothing justifies it, we will tell you so.
Request a pre-audit If an engagement goes ahead, the comparative study of the eight precedents, with supporting sources, will be provided to you with the diagnosis.The information on this page is based on foreign precedents and on texts under discussion as at 12 October 2026. It constitutes neither personalised advice, nor investment advice, nor a forecast; each situation calls for its own analysis.