“Since January 1, 2026, the single flat-rate levy (PFU), commonly referred to as under the term « "Flat Tax", applicable to capital income, is brought …
— Kahafoa Desiré Ouattara
➢ « Flat Tax » : what are you talking about?
The « Flat Tax » or single flat-rate levy (PFU), is the mechanism for proportional taxation of the main capital income established in France. by the finance law for 2018, in a logic of simplification and competitiveness. tax under the presidency of Emmanuel Macron.
Between 2018 and 2025, this overall rate was set at à 30%, composed of 12.8% income tax and 17.2% social security contributions. Since January 1, 2026, it rises to 31.4%, following the increase in the CSG, which brings social security contributions to 18.6%, the share of income tax remaining unchanged.
The legal structure of the system therefore remains identical, only its intensity remains unchanged. Contributory contribution has been made. increased, reflecting a strengthening of the participation of capital income in the financing of social protection.
➢ A social increase with direct tax implications
The increase in the Flat Tax results from the law on financing security. social for 2026. Indeed, if the « income tax » remains unchanged, social security contributions increase by 17.2% in 18.6%, under the effect of the increase in the CSG.
However, the legal basis of the system is not changed. Codified à Article 200 A of the General Tax Code, the Flat Tax continues to apply automatically to dividends, interest and movable capital gains, unless there is a global and annual option for the progressive income tax scale. In other words, the tax mechanism remains intact.
On the other hand, the economic balance of the device is affected. The reform, resulting from a security financing law, social and not a finance law, mobilizes social leverage and correspondingly increases the share of social contributions in the taxation of capital. Thus, without altering its legal architecture, the Flat Tax sees its scope influenced by a strengthening of the contribution of property income to the financing of social protection.
In a context of budgetary constraints, this choice is not neutral with regard to the principle of equality. before public charges and the articulation between taxation and capital and taxation work.
➢ Dividends: profitable profitability net mechanically amputated
From the outset, the impact is perceptible for individuals: a dividend of &euro 10,000; now costs €3,140; of direct debits, against 3,000 € previously. À On the scale of an isolated distribution, the variation may seem contained. On the other hand, applied to large amounts or more regular flows, it significantly alters the net return.
It is then important to note that the increase results exclusively from social security contributions. Through this, the « social » The taxation of capital is increased, which accentuates the duality of capital. between tax and social contribution, without the overall economic burden being reduced.
From this perspective, shareholder managers must think in consolidated rates. As soon as the benefit is fully distributed, the IS + PFU accumulation mechanically raises the effective withholding rate. The gap with taxation salary remuneration is thus tightening, without disappearing.
➢ Remuneration/dividend arbitrage: a reopened calculation
The Flat Tax of 2018 had, through its stability, and its readability, security and safety. distribution strategies. With a PFU worn à 31.4%, the arbitration between remuneration and dividends finds a finer analytical dimension.
In principle, the dividend is less loaded than the dividend. in social contributions than the salary (except in the case of majority managers of SARL, for whom the fraction exceeding 10% of the capital, resignation premiums and current accounts remains subject to social contributions). However, the net gap is narrowing.
Above all, remuneration opens up social rights (retirement, illness, welfare, possibly unemployment insurance) which do not exist with the dividend. Therefore, the analysis cannot be exclusively fiscal: it must integrate the insurance and heritage dimension.
Thus, the decision depends more than ever on a global approach integrating:
• the manager's marginal tax rate,
• effective social pressure,
• heritage strategy long term,
• and the logic of capitalization in society.
➢ The option for the progressive scale: a reactivated strategic lever
The option for the progressive scale retains its global and irrevocable character for all income concerned for the year. It is neither compartmentalized nor adjustable position by position.
In this new context, this option deserves renewed attention. Indeed, for taxpayers whose marginal tax rate is lower than 12.8%, or benefiting from significant reductions, in particular the 40% reduction on eligible dividends, taxation at the scale can lead to an overall load lower than the PFU of 31.4%. For taxpayers located in the high brackets (30%, 41%, 45%), the PFU generally remains more protective.
Thus, the increase in the CSG reactivates a real comparative logic around the Flat Tax: the automaticity of the tax. gives way to the simulation.
➢ Investment envelopes: differentiated effects
The increase in the Flat Tax does not uniformly affect supports.
• Ordinary securities account: fully exposed at the rate of 31.4%, except option for the scale. Its attractiveness relative serode.
• PEA: after five years, exemption from income tax; only social security contributions of 18.6% are due. The differential with the PFU increases, reinforcing its structural interest.
• Life insurance: independent plan, with reductions after eight years (€4,600 or €9,200 depending on family situation).
It is also important to remember that certain income remains outside the scope of the Flat Tax: property income, real estate capital gains, regulated savings products or PEL/CEL under specific regimes. The increase cannot therefore be assimilated to a general increase in taxation; heritage.
➢ Towards a silent recomposition of balances?
The increase of the PFU to 31.4% does not constitute a break: its legal architecture and its flat-rate logic remain intact. However, the economic balances on which many heritage strategies were based are being modified.
By strengthening the social share of capital taxation, the legislator reopens the question of neutrality of capital. between capital and labor. If the budgetary objective is immediate, the issues of coherence and attractiveness arise. could, at agrave; term, settle down new.
Thus, the 2026 sequence recalls a reality constant: in taxation capital, stability is relative. The Flat Tax remains, but its equation is evolving.
