Le Figaro : pourquoi la taxe sur les holdings est un retour «déguisé» de l’ISF p

Budget 2026 : pourquoi la taxe sur les holdings est un retour «déguisé» de l’ISF pour les concernés

DÉCRYPTAGE - Dans le même esprit que celui de la taxe Zucman, la mesure proposée dans le budget par le gouvernement entend viser les plus fortunés via le patrimoine des sociétés qu’ils détiennent.

Beaucoup d’experts l’affirment : « Un holding, en droit français, ça n’existe pas. » Effectivement, le nouveau dispositif mis en avant par le gouvernement dans son budget déposé ce mardi vise un type d’entreprise qui n’a pas de définition formelle : les holdings familiaux. Concrètement, l’article 3 du projet de loi de finances (PLF) - qui court sur cinq pages tant le dispositif est complexe - prévoit de créer une taxe de 2 % sur « les actifs non professionnels détenus par les sociétés ayant leur siège en France ». Pour être redevables de cette taxe, les entreprises doivent être valorisées à plus de 5 millions d’euros, une personne ou une famille doivent en détenir 33 %, et leurs revenus doivent majoritairement être des revenus financiers (dividendes, plus-values…).

Selon le PLF 2026, ce nouvel impôt vise à « assurer une juste contribution des personnes les plus fortunées qui recourent à ce type de montage » pour « échapper à l’impôt ». En effet, les propriétaires de holdings peuvent parfois y conserver les revenus financiers que génère le patrimoine de l’entreprise. Ce faisant, ils ne se distribuent pas de dividendes et échappent de facto à l’imposition des revenus financiers (le prélèvement forfaitaire unique, notamment). Ainsi le dispositif imaginé par Bercy vise à imposer ce patrimoine « thésaurisé » dans les « holdings ».

«Une taxe confiscatoire»

Pour ce faire, il considère l’ensemble du patrimoine des sociétés concernées, en excluant de l’assiette de calcul « les titres de participation dans les sociétés dont le holding détient 5 % ou plus », explique Yoan Chemama, avocat associé au cabinet Arsene. En cela, il se rapproche de l’ISF (impôt de solidarité sur la fortune), disparu en 2018 et remplacé par l’IFI (impôt sur la fortune immobilière). Et il taxe non pas des revenus mais un patrimoine en ciblant les plus aisés. 

« Les ménages propriétaires des entreprises qui seront redevables de la taxe constituent une population qui aurait probablement été soumise à l’ISF à l’époque », confirme l’avocat. Toutefois, la cible affichée du nouvel impôt est beaucoup plus réduite que celle de son ancêtre. L’article 3 du PLF cite explicitement les « environ 4000 ménages les plus fortunés ». L’exécutif espère que cette nouvelle taxe rapportera environ 1 milliard d’euros dès l’an prochain à l’État. Si seulement 4000 ménages s’en acquittent, leur facture risque d’être salée (250 000 euros en moyenne).

Contrairement à l’ancien ISF, le dispositif sur les holdings n’est pas plafonné. Ainsi, « en l’absence de plafonnement en fonction du résultat de l’année correspondant au rendement du patrimoine du holding, celui-ci pourrait être contraint d’en vendre une partie pour s’acquitter de la taxe », souligne Me Chemama. Ainsi, « c’est une taxe confiscatoire car non plafonnée et non déductible de l’assiette de l’Impôt sur les sociétés » ce qui peut créer une double imposition, tranche Vincent Lazimi, avocat associé au cabinet Jeantet.

L’assiette de la « taxe holding » se rapproche aussi beaucoup de celle de l’ISF, qui taxait le patrimoine financier des individus en excluant « l’outil de travail », c’est-à-dire les actifs se rapportant aux sociétés au sein desquelles les contribuables concernés exerçaient des fonctions de direction. La nouvelle taxe, qui, pour sa part, s’applique aux sociétés, vise aussi le patrimoine financier et en exclut de fait « les actifs qui se rapportent aux entreprises dans lesquelles le holding exerce une certaine influence », décrypte l’avocat du cabinet Arsene. L’expert du cabinet Jeantet qualifie d’ailleurs le dispositif d’« ISF déguisé » et souligne que son taux est plus sévère que celui de l’ancien impôt sur les fortunes (celui-ci atteignait 1,5 % maximum).

Un outil qui inquiète

En plus de l’imposition des holdings français, le texte prévoit que « la taxe sera également due par les résidents français qui détiennent des holdings situés à l’étranger ». Sur ce point, la logique du dispositif est quelque peu fragile, dans la mesure où « pour les holdings étrangers, elle conduit à taxer des particuliers (contribuables français, NDLR) au titre d’un impôt conçu pour les sociétés », remarque Vincent Lazimi qui estime qu’un tel procédé est « discriminatoire » par rapport aux holdings français.

Pire encore, comme le seuil de participation pour être redevable est de 33 % et non pas 50 %, l’administration fiscale pourrait se retrouver à imposer un résident français sur des dividendes non distribués par une société étrangère, alors même que celui-ci n’a pas le pouvoir de décider d’une distribution. « Dans ce cas, un particulier français devra-t-il vendre sa maison pour payer la taxe sur les holdings ? », s’interroge un expert.

Une chose est sûre : ce nouvel outil inquiète. « Depuis la publication du budget, je suis sollicité en permanence par des clients anxieux de savoir comment la taxe va impacter leur holding », confie un fiscaliste. Pour l’instant, cette source tente de « garder la tête froide ». « Pour l’heure, cette taxe n’est qu’un projet qui va sans doute évoluer », tempère Antoine Vergnat, avocat associé au cabinet McDermott Will & Schulte.

Voici ce que payent déjà les Français les plus aisés : http://www.lefigaro.fr/conjoncture/alors-que-l-isf-revient-sur-la-table-voici-ce-que-payent-deja-les-francais-les-plus-aises-20250926

The Guardian : Rachel Reeves says higher taxes on wealthy ‘part of the story’ fo

Rachel Reeves says higher taxes on wealthy ‘part of the story’ for November budget
Exclusive: Chancellor hints at rises and calls out past ‘scaremongering’ over VAT on private schools and changes to non-doms

Rachel Reeves has said higher taxes on the UK’s wealthy will form part of next month’s budget, as she shrugged off the “scaremongering” and “bleating” of her critics, and stressed her determination to repair the public finances.

Speaking in Washington, where she is attending the annual meetings of the International Monetary Fund (IMF), the chancellor told the Guardian there “won’t be a return to austerity” and hinted at tax increases for the most well-off.

A correspondent from HM Revenue and Customs.A correspondence from HM Revenue of Customs. The British government department for the collections of taxes and custom duties.

Reeves is expected to announce a package of tax rises on 26 November, in response to a downgrade in future growth forecasts from independent forecaster the Office for Budget Responsibility (OBR).

Asked whether higher taxes on the wealthy would feature, the chancellor said “that will be part of the story”.

She added: “Last year, when we announced things like the non-doms, like the [tax increase for] private equity, like the VAT on private school fees, there was so much bleating that it wasn’t going to raise the money – that people would leave.

“The OBR will publish updated numbers on all of those things. And that scaremongering didn’t pay off, because this is a brilliant country and people want to live here. And I think, when people scaremonger again this year, we should take some of that with a pinch of salt.”

Reeves has previously ruled out imposing a new “wealth tax” but campaigners for changes to the system have highlighted other options, including: raising the rate of capital gains tax; levying national insurance on rental income and on partners in law firms and consultancies; and creating higher council tax bands.

There is also speculation she will revive plans to overhaul tax-free Isas to divert cash towards the UK stock market.

Reeves declined to comment on specific measures, though she stressed the package would be aimed at boosting economic growth, as well as raising revenue.

Last year’s budget included an historic £40bn of tax increases and fuelled a furious backlash from business, which bore the brunt of the rise in national insurance contributions.

Asked whether spending cuts would form part of the budget package, Reeves pointed to potential cost-savings from the use of new technologies; but stressed that departmental budgets had been set in this year’s spending review.

She hopes to deliver a decisive budget which will persuade bond markets to lower the UK’s borrowing costs and she repeatedly contrasted her approach of sticking to Labour’s investment plans in the face of the deteriorating outlook, with the approach of the Conservatives and Reform.

“In the budget next month, there won’t be a return to austerity. We know that we face a changing global environment in terms of the economy at the moment. But last year, I put investment in, to reduce waiting lists, to build housing, to build the energy infrastructure to get people’s bills down sustainably, not through quick fixes, and we’ll stick to that course.”


Asked how she would explain the need for further tax rises, Reeves said she hoped the public would recognise the global economic outlook had darkened.

“I think people can see that this year, in 2025, the world’s been a very, very volatile place,” she said. “You turn on your TV every night, it might not always be about the economy, but every night, one of the top two or three stories on the news is going to be around some sort of global tensions that is having repercussions at home. So I think that the British people recognise all of that.”

She added: “I’m being honest and I think the British people respect that and it means I’m not always able to offer the easy answers and the platitudes and the false promises.”

However, she criticised the OBR for the politically awkward timing of its productivity review, coming after Reeves carried out a spending review in June. “I think that it would have been a lot better if they had adjusted their forecasts the year before the election, or even last summer, to enable the new government to really understand the economic position.”

The OBR reviewed its forecasting model over the summer, focusing on the outlook for productivity, which has been undershooting OBR projections for several years.

Reeves said: “Those forecasts are going to change this year, but it does reinforce what I said all the way through the election campaign, that the number one priority of this government is to grow the economy.”

She pointed to the Tories’ policy of austerity and the impact of Brexit as the key factors behind the UK’s weak productivity record, which stretches back to the global financial crisis of 2008.

Experts expect the independent forecaster to say the public finances look £10bn-£20bn weaker in five years’ time, than it believed at the spring statement in March. That downgrade comes in addition to the £10bn cost of Labour’s U-turns on the winter fuel allowance, and botched reforms to disability benefits.

As well as closing that gap, Reeves is expected to use the budget to build up greater headroom against her fiscal rules, to cushion the UK against volatility in government bond markets, which has a knock on effect on the Treasury’s borrowing costs.


When the £10bn margin for error she allowed herself in last year’s budget looked set to be wiped out at the time of the spring statement, she chose to respond with welfare cuts – which were subsequently rejected by Labour MPs. She believes a larger buffer will contain the impact of market jitters on policymaking.

Reeves said by getting a grip on the finances, she hopes to convince investors to close the gap that emerged between the UK’s borrowing costs and those of other large economies at the time of Liz Truss’s disastrous mini-budget in 2022.

“When Liz Truss and Kwazi Kwarteng did their mini-budget three years ago, our bond yields decoupled from other G7 economies and they are still at an elevated level compared to other countries. I want to bring us back in line.”

She said that the UK now spends more than £100bn a year on interest alone – with much of it going to overseas investors.

“If you say to people, ‘What would you like to spend more on?’ They’re going to say, schools, hospitals, police on our streets, parks, and local facilities. No one’s going to say, ‘We’re keen that we spend more on servicing our debt to US hedge funds. And yet that is the item of spending that went up the most under the previous government, and there is absolutely nothing progressive about it,” she said.

“I’m providing that confidence to people who buy government bonds that I’ve got a grip on the public finances. And if we can continue to do that, I am convinced we can bring down those borrowing costs.”

Reeves flew into Washington presenting the UK as a “beacon of stability”. But the IMF’s latest forecasts, published as the annual meetings kicked off, showed UK consumers suffering the highest inflation rate in the G7 this year and next.

FT Lex : The stage is set for luxury’s long-awaited upswing

The stage is set for luxury’s long-awaited upswing
LVMH’s third-quarter sales provided evidence of a turnaround in the sector’s fortunes

The key skill for the eagle-eyed luxury customer is to identify which among the many nascent trends has staying power, and then zero-in on the product that best captures the zeitgeist. Luxury investors attempting the same feat will find their eyes alight on Bernard Arnault’s LVMH.

The industry bellwether’s third-quarter sales provided early evidence of a turnaround in the sector’s fortunes. Revenues at its key fashion and leather goods division, which houses such brands as Louis Vuitton and Dior, are still falling — by 2 per cent in the third quarter. But the rate of decline has slowed from 9 per cent the quarter before. That suggests we may finally be nearing the trough in overall luxury spending.

A turn in the luxury cycle would be good news for companies across the sector, and helps explain why LVMH’s results not only lifted its own stock price by 14 per cent on Wednesday but also nudged up those of Hermès, Burberry and Gucci-owner Kering. However, the behemoth should benefit disproportionately. 

For one thing, handbags and frocks — to which the group is overweighted with its massive LV brand — are set to do better than rocks. Jewellery has outperformed so-called “soft” luxury recently, growing 4 per cent a year between 2022 and 2025 while the latter was flat, according to RBC analysis, so there is room for a catch-up. 

Better still, fashion and leather goods brands have taken steps to improve their value proposition, which had suffered from a combination of price hikes and unexciting design. “Value for money” may sound like a quaint concept in an industry that persuades customers to part with thousands of dollars in exchange for wisps of exquisitely crafted gauze. But even the super wealthy, as it turns out, don’t like to feel that they are being taken for a ride.


Now, the industry has moderated its price increases. Indeed, LVMH’s improvement this quarter was mainly due to volume, rather than mark-ups. And broader inflation has caught up with LVMH’s price hikes in France and the US, according to Bernstein analysis. Meanwhile, new designers are creating some buzz. 

Granted, the luxury upswing — when it comes — will be less ebullient than the one the industry experienced after the pandemic. It will be a while before brands can inflate their prices and still sell baubles by the truckload. And LVMH isn’t the only maison that is poised to benefit from a soft-luxury revival, or the only one with new design talent to showcase. Demna Gvasalia at Gucci has also had an encouraging start.


But LVMH’s stock has taken a beating in the slump. This summer, it reversed its historical premium to trade at a discount to the S&P Global Luxury Index on a price to forward earnings multiple, and is now only just above the pack. Kering and Burberry, meanwhile, have priced in part of their turnarounds already. And, while the benefits of the group’s heft aren’t immediately visible in a downturn, when throwing cash around fails to translate into sales, having the money to back its vision stands it in good stead for when the cycle turns.

The Information : The Other Bubble

If there is a bubble in artificial intelligence, much of the blame can be placed on Wall Street, not Silicon Valley.

Financial markets are as frothy as they can be, and the appetite for risk appears to be insatiable. That’s why Sam Altman has been able to get otherwise rational companies and investors to fund his audacious growth plans. On Tuesday, we got the latest evidence of a financial bubble when Wall Street’s giants posted numbers bankers dream about.

Goldman Sachs’ dealmakers and traders are on track for their best year ever. At BlackRock, assets under management rose nearly $1 trillion in just one quarter to $13.5 trillion. Some of this is due to the AI boom, as nothing happens in isolation. BlackRock runs lots of index funds, and the big market indices are more concentrated than ever in names like Nvidia and Microsoft that are deeply embedded in AI. Index funds account for more than half of the fund market.

Still, big drivers in finance are pumping more air into AI. The bond market, which has grown increasingly important to the tech industry, is going full speed ahead. The difference between the yields offered by safe government bonds and those of corporate and junk bonds, which have a higher risk of default, is among the smallest in years. That means investors need to go elsewhere to get higher yields. How about some CoreWeave debt that yields 8.5%? Never mind that the data center company occupies one of the riskiest niches in the AI buildout.

Private debt managers have roughly $3 trillion in assets, a 50% rise in five years, and need to justify their existence by producing better returns than bonds. That often means making riskier loans.

There are other telltale signs of exuberance on Wall Street. One of the best strategies for companies to boost their stock prices this year was to jettison their old business models and buy up as much crypto as possible, often borrowing money to do so. Chipmakers that sign deals with AI companies also get a boost, even though the buyers of the chips have no clear ability to pay for them.

Then there’s the pressure to put money to work. Globally, roughly $2.5 trillion of dry powder is sitting in private equity firms. That explains the record $55 billion buyout of Electronic Arts. Big-ticket buyouts have long been a sign that a market cycle has topped out.

We could go on. The AI bubble couldn’t have happened if markets were dismal. Altman, Elon Musk and the other AI executives sucking up cash would be talking much smaller numbers if investors were worried about risk.

AI’s cash needs and the frothy markets were made for each other. It’s hard to believe either can exist without its partner.

TechCrunch : You can now text Spotify’s AI DJ

You can now text Spotify’s AI DJ

Spotify on Wednesday upgraded its AI DJ feature — available to Premium subscribers — with a handful of new features, including the ability to send in your requests by typing, not just using voice commands.

The feature works with both English and Spanish requests, as Spotify’s Spanish-language DJ, called DJ Livi, now accepts music requests.

The AI DJ feature was updated earlier this year to accept voice requests, instead of only playing tunes Spotify thinks that you’ll like. However, that feature was only available to the English-language AI DJ until today.

Texting with an AI assistant is now a common behavior, thanks to the rising popularity of AI chatbots like ChatGPT and Gemini. These services allow for multi-modal inputs, meaning you can either talk, text, or upload images and files as part of your request. As more people have gotten used to shifting back and forth between input methods, Apple rolled out a version of its Siri assistant that can also be reached by text.

It’s a natural next step for Spotify’s AI feature to accept text input, as well, given that users are often engaged with the streaming service when out and about, commuting, or in a quiet space where they don’t want to disturb others by issuing voice commands.

In addition to the new texting feature, Spotify says that the AI DJ will also now offer personalized prompt suggestions to help inspire you if you’re not sure what you want to listen to next.

To access the DJ, you simply search for the term “DJ” on Spotify and then press play to start your curated selection of music. If you want to change the music, you can tap the DJ button in the bottom-right of the screen, then offer your suggestion via voice or text.

Spotify notes the DJ can handle requests that combine genre, mood, artist, or activity. The feature is currently live in English and Spanish in over 60 markets worldwide.

FT : UK energy bosses sound warning over rising household bills

UK energy bosses sound warning over rising household bills
Octopus Energy, EDF and E.On executives challenge Labour’s pledge to reduce energy costs

The UK’s leading energy retailers have warned of rising electricity prices, in a challenge to Labour’s pledge to bring household bills down by hundreds of pounds by 2030. 

Executives from Octopus Energy, the UK’s largest household energy supplier, as well as major suppliers EDF and E.On said the increasing cost of investment added on to bills risked outweighing any potential falls in wholesale prices.

“If we continue on the path we are on, in all likelihood electricity prices are going to be 20 per cent higher — even if wholesale prices halve,” Rachel Fletcher, director of regulation at Octopus Energy, told the parliamentary Energy Select Committee on Wednesday.

“Non-commodity costs are adding about £300 [a year] of pressure,” she added.

The comments come as Labour is under pressure over energy costs, with critics warning that the government’s decarbonisation targets for the electricity sector are unachievable and risk pushing up charges.

British households pay much more for electricity than for gas, both on the unit rate and the daily standing charge. 

The retail electricity price includes the wholesale price of electricity, as well as extra charges to pay for government policies such as supporting vulnerable households, renewable electricity subsidies and upgrading electricity networks. 

Network owners are making huge investments in expanding and upgrading grids, with demand predicted to increase as households are encouraged to buy electric cars and heat pumps.

The government is also offering generous price guarantees to new wind farms, while households and businesses will also be charged for developing the Sizewell C nuclear power plant through a levy. 

However, Simone Rossi, chief executive of EDF UK’s energy business, told the committee that electricity demand had fallen 8 per cent since before the coronavirus pandemic, which has spread costs across a smaller base.

“Even if the wholesale price were to halve, bills will rise,” he said, adding that the cost of serving customers in Britain is roughly double that of France.   

Chris Norbury, chief executive of E.ON UK, said some of the modelling suggested “we could get to a position by 2030 where if the wholesale price was zero, bills would still be the same as they are today”, due to “non-commodity costs” from increased spending on policy and the network.

During its 2024 election campaign, Labour pledged to reduce total energy bills, which for most households include gas and electricity, by £300 a year by 2030. 

However, the party has also pledged to decarbonise the electricity sector by 2030, requiring huge investment in new networks and generation capacity.

Fletcher called for a review of electricity transmission investment plans. “Ofgem is very close to effectively agreeing that we need to spend £80bn on electricity transmission over the next five years,” she said.

She added this could add roughly £100 to a typical electricity user’s bill over the next four years or so. “It is undoubtable we need more electricity transmission. But I think there are huge question marks over do we really need £80bn worth,” Fletcher said.

The energy department did not immediately respond to a request for comment.

FT : Austrian property tycoon René Benko sentenced to two years in jail

Austrian property tycoon René Benko sentenced to two years in jail
Fraud trial likely to be first in a series of cases related to the collapse of real estate group Signa

René Benko has been sentenced to two years in prison after a court in Innsbruck found the Austrian real estate magnate guilty of insolvency-related fraud.

The two-day trial was the first of what is likely to be a series of court cases for the founder of property group Signa, which collapsed two years ago.

Prosecutors alleged that, as his empire neared collapse in late 2023, Benko improperly shifted money through transactions including an advance rental payment of €360,000 and a €300,000 gift to his mother.

The court ruled that the €300,000 transfer during insolvency proceedings was an attempt to hide assets from creditors. He was acquitted on a second charge related to the alleged rental advance.

Benko, who has been in pre-trial detention in Vienna since January, had faced up to 10 years in prison.

As the first criminal conviction tied to the downfall of Benko’s real estate empire, the verdict is a central moment in one of the most spectacular corporate downfalls in recent European history. The Austrian businessman’s network of property and retail holdings spanned from Vienna to Berlin and New York.

The case forms part of a wider investigation into the failure of Signa, which caught out banks, sovereign wealth funds and family offices that lent more than €15bn to entities in the group.

Prosecutors continue to investigate broader allegations of asset concealment, breach of trust and investor deception related to the group’s collapse.

New charges against Benko last month accused of him of hiding €120,000 in cash along with items including watches and cufflinks worth almost €250,000 in the home of a relative to keep them from creditors.

Prosecutors moved quickly on the first case because it has a narrow focus on alleged transfers and concealments in Benko’s personal insolvency, rather than expediting the wider probe of the cross-border collapse of Signa group.

Benko denies all wrongdoing and is expected to appeal against the ruling by the regional trial court.

The Public Prosecutor’s Office for the Prosecution of Economic Crimes and Corruption and Benko’s legal counsel could not immediately be reached for comment. His lawyer has previously dismissed the allegations as “false”.

FT : Austrian property tycoon René Benko sentenced to two years in jail

Austrian property tycoon René Benko sentenced to two years in jail
Fraud trial likely to be first in a series of cases related to the collapse of real estate group Signa

René Benko has been sentenced to two years in prison after a court in Innsbruck found the Austrian real estate magnate guilty of insolvency-related fraud.

The two-day trial was the first of what is likely to be a series of court cases for the founder of property group Signa, which collapsed two years ago.

Prosecutors alleged that, as his empire neared collapse in late 2023, Benko improperly shifted money through transactions including an advance rental payment of €360,000 and a €300,000 gift to his mother.

The court ruled that the €300,000 transfer during insolvency proceedings was an attempt to hide assets from creditors. He was acquitted on a second charge related to the alleged rental advance.

Benko, who has been in pre-trial detention in Vienna since January, had faced up to 10 years in prison.

As the first criminal conviction tied to the downfall of Benko’s real estate empire, the verdict is a central moment in one of the most spectacular corporate downfalls in recent European history. The Austrian businessman’s network of property and retail holdings spanned from Vienna to Berlin and New York.

The case forms part of a wider investigation into the failure of Signa, which caught out banks, sovereign wealth funds and family offices that lent more than €15bn to entities in the group.

Prosecutors continue to investigate broader allegations of asset concealment, breach of trust and investor deception related to the group’s collapse.

New charges against Benko last month accused of him of hiding €120,000 in cash along with items including watches and cufflinks worth almost €250,000 in the home of a relative to keep them from creditors.

Prosecutors moved quickly on the first case because it has a narrow focus on alleged transfers and concealments in Benko’s personal insolvency, rather than expediting the wider probe of the cross-border collapse of Signa group.

Benko denies all wrongdoing and is expected to appeal against the ruling by the regional trial court.

The Public Prosecutor’s Office for the Prosecution of Economic Crimes and Corruption and Benko’s legal counsel could not immediately be reached for comment. His lawyer has previously dismissed the allegations as “false”.