What is a real estate holding company?

A real estate holding company is a parent company that owns shares in one or more property companies (SCIs). It centralizes management, optimizes taxation through the parent-subsidiary regime, and facilitates estate planning and asset protection.

What are the advantages of a holding company?

Key advantages include: 95% dividend tax exemption (parent-subsidiary regime), tax consolidation between subsidiaries, optimized estate planning through share dismemberment, asset protection via legal separation, and reinvestment capacity without personal taxation.

How does the parent-subsidiary regime work?

The parent-subsidiary regime allows a holding company to receive dividends from subsidiaries with 95% tax exemption. Only 5% is taxed as management fees. Conditions: hold at least 5% of shares for 2+ years, both companies subject to corporate tax (IS).

What is a real estate holding company?

A real estate holding company is a corporation (usually SAS or SARL) that holds shares in SCIs or other real estate companies. It allows centralizing management, optimizing taxation and facilitating real estate wealth transmission.

What are the advantages of a real estate holding?

The main advantages are: the parent-subsidiary regime (95% exemption on dividends received), tax integration, leverage for new acquisitions, facilitated share transmission and asset protection.

What is the cost of creating a real estate holding?

Creation costs include legal fees (€1,500 to €5,000), annual accounting fees (€2,000 to €5,000/year) and potential restructuring costs. A holding becomes relevant from approximately €500,000 in real estate assets.

Corporate tax or income tax holding: which option to choose?

A corporate tax holding is preferred for capitalizing and reinvesting (reduced rate of 15% up to €42,500 in profit). An income tax holding is fiscally transparent and may be suitable for the early years or rental deficit strategies.

What is the Dutreil Pact for wealth transmission?

The Dutreil Pact (Art. 787 B CGI) provides a 75% exemption on donation or inheritance taxes on holding shares. It requires a 2-year collective conservation commitment followed by a 6-year individual commitment after the donation (LF 2026). The holding must be an active holding with eligible activities.

Holding company vs LMNP: which structure to choose?

A corporate tax holding is preferable for portfolios over €500K with long-term capitalization and optimized transmission goals (Dutreil -75%). LMNP real regime is better suited for individual investors thanks to property depreciation and income tax with 17.2% social contributions. The choice depends on the amount invested, holding period and transmission goals.

How does the CDHR work with a holding?

The High Income Differential Contribution (CDHR) of 20% applies when your reference tax income exceeds €250,000 (single) or €500,000 (couple). Dividends distributed by the holding increase your reference income. The smoothing strategy involves spreading distributions over several years to stay below the threshold.

What is the share contribution-sale mechanism (Art. 150-0 B ter)?

The share contribution-sale mechanism allows deferring capital gains tax when contributing shares to the holding. The deferral is maintained if the holding reinvests 60% of the sale price in an economic activity within 24 months. This frees up cash for new investments without immediate taxation.

What is a real estate holding company?

A real estate holding company is a corporation (usually SAS or SARL) that holds shares in SCIs or other real estate companies. It allows centralizing management, optimizing taxation and facilitating real estate wealth transmission.

What are the advantages of a real estate holding?

The main advantages are: the parent-subsidiary regime (95% exemption on dividends received), tax integration, leverage for new acquisitions, facilitated share transmission and asset protection.

What is the cost of creating a real estate holding?

Creation costs include legal fees (€1,500 to €5,000), annual accounting fees (€2,000 to €5,000/year) and potential restructuring costs. A holding becomes relevant from approximately €500,000 in real estate assets.

Corporate tax or income tax holding: which option to choose?

A corporate tax holding is preferred for capitalizing and reinvesting (reduced rate of 15% up to €42,500 in profit). An income tax holding is fiscally transparent and may be suitable for the early years or rental deficit strategies.

What is the Dutreil Pact for wealth transmission?

The Dutreil Pact (Art. 787 B CGI) provides a 75% exemption on donation or inheritance taxes on holding shares. It requires a 2-year collective conservation commitment followed by a 6-year individual commitment after the donation (LF 2026). The holding must be an active holding with eligible activities.

Holding company vs LMNP: which structure to choose?

A corporate tax holding is preferable for portfolios over €500K with long-term capitalization and optimized transmission goals (Dutreil -75%). LMNP real regime is better suited for individual investors thanks to property depreciation and income tax with 17.2% social contributions. The choice depends on the amount invested, holding period and transmission goals.

How does the CDHR work with a holding?

The High Income Differential Contribution (CDHR) of 20% applies when your reference tax income exceeds €250,000 (single) or €500,000 (couple). Dividends distributed by the holding increase your reference income. The smoothing strategy involves spreading distributions over several years to stay below the threshold.

What is the share contribution-sale mechanism (Art. 150-0 B ter)?

The share contribution-sale mechanism allows deferring capital gains tax when contributing shares to the holding. The deferral is maintained if the holding reinvests 60% of the sale price in an economic activity within 24 months. This frees up cash for new investments without immediate taxation.

Real Estate Holding Simulator

Understanding real estate holding

A real estate holding is a company (SAS, SARL, SCI with IS) that holds shares in other real estate companies. This structure allows you to optimize taxation, facilitate wealth transmission and pool cash between different real estate activities.

Real estate holding structure

HOLDING (SAS/SARL)

Parent company - IS 25%

SCI Building A

Residential rental

SCI Building B

Offices

SCI Building C

Retail

Parent-subsidiary regime: the key tax advantage

Almost total dividend exemption

When the holding owns at least 5% of a subsidiary for 2 years, dividends received are 95% exempt from corporate tax.

Example:

Dividend received: €100,000 → Tax base: €5,000 (cost share) → IS at 25% = €1,250 (vs €25,000 without the regime)

Holding advantages

Parent-subsidiary regime: Almost tax-free dividends
Tax integration: Results compensation
Cash pooling: Treasury pooling
Transmission: Donation of holding shares
Protection: Risk compartmentalization between subsidiaries

Disadvantages to know

Structure costs: Annual accounting, legal
Complexity: Managing multiple entities
Double taxation: Cash withdrawal to individual
Profitability threshold: Relevant from €500K wealth
Abuse of law: Structure must have economic substance

When to create a holding?

A holding is recommended if you own more than €500,000 in real estate, if you have multiple SCIs/companies, or if you want to prepare the transmission of your wealth. Consult an accountant and a tax lawyer to validate the relevance of the structure.

Understanding real estate holding

Real estate holding structure

HOLDING (SAS/SARL)

Parent company - IS 25%

SCI Building A

Residential rental

SCI Building B

Offices

SCI Building C

Retail

Parent-subsidiary regime: the key tax advantage

Almost total dividend exemption

When the holding owns at least 5% of a subsidiary for 2 years, dividends received are 95% exempt from corporate tax.

Example:

Dividend received: €100,000 → Tax base: €5,000 (cost share) → IS at 25% = €1,250 (vs €25,000 without the regime)

Holding advantages

Parent-subsidiary regime: Almost tax-free dividends
Tax integration: Results compensation
Cash pooling: Treasury pooling
Transmission: Donation of holding shares
Protection: Risk compartmentalization between subsidiaries

Disadvantages to know

Structure costs: Annual accounting, legal
Complexity: Managing multiple entities
Double taxation: Cash withdrawal to individual
Profitability threshold: Relevant from €500K wealth
Abuse of law: Structure must have economic substance

When to create a holding?

Real Estate Holding Simulator

Understanding real estate holding

Real estate holding structure

Parent-subsidiary regime: the key tax advantage

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Real Estate Holding Simulator

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Parent-subsidiary regime: the key tax advantage

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Parent-subsidiary regime: the key tax advantage

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