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Two-euro coin — dividend taxation in France and Europe in 2026

Dividend Tax in France 2026: Now in Europe’s Top 6 at 35.4%

Oct 23
5 min read

Since 1 January 2026, the maximum tax rate on dividends received by an individual resident in France has reached 35.4%. France now ranks sixth in Europe, far above the continental average of 21%. A quiet change with heavy consequences for company directors, family shareholders and taxpayers who move between France and Switzerland.


Two-euro coin — dividend taxation in France and Europe in 2026: 31.4% flat tax plus CEHR surtax

I. How did the rate go from 30% to 35.4%?


The prélèvement forfaitaire unique (PFU), the French “flat tax” introduced in 2018, used to combine 12.8% income tax and 17.2% social charges, i.e. 30%.


The Social Security Financing Act for 2026 (Law no. 2025-1403 of 30 December 2025) raised the CSG rate on capital income by 1.4 points, from 9.2% to 10.6%, as a new financial contribution for autonomy. Social charges on investment income therefore reach 18.6%, and the flat tax 31.4%. The measure applies from the taxation of 2025 income for income from assets and, for investment products such as dividends, to income received from 1 January 2026.


For the wealthiest households, the exceptional contribution on high incomes (CEHR, Article 223 sexies of the French Tax Code) is added: 3% on the portion of the reference taxable income between €250,000 and €500,000 for a single person (€500,000 to €1m for a couple), then 4% above. Because dividends are included in the reference taxable income, a director who pays himself substantial dividends quickly crosses these thresholds.


How the maximum rate is calculated 12.8% (income tax) + 18.6% (social charges) = 31.4% flat tax 31.4% + 4% (CEHR, top bracket) = 35.4% Below the CEHR thresholds the rate remains 31.4%; it is 34.4% in the 3% bracket.

One useful clarification: the differential contribution on high incomes (CDHR), which guarantees a minimum 20% effective tax, is a floor, not a surtax. It does not come on top of the 35.4%.


II. France compared with its neighbours


Data compiled by the Tax Foundation (March 2026, from OECD and PwC sources) show the gap. Only five European countries tax individuals’ dividends more heavily:


  • Ireland: 51%

  • Denmark: 42%

  • United Kingdom: 39%

  • Norway: 38%

  • Netherlands: 36%


Then comes France (35.4%), followed by a group of major economies well below: Sweden, Spain and Belgium (30%), Austria and Portugal (28%), Germany and Italy (26%), Switzerland and Iceland (22%), Luxembourg (21%). At the other end, Estonia, Latvia and Malta do not tax dividends in the hands of the individual, as tax is levied at company level.


The European average stands at 21%. France is therefore 14 points above it — and 13 points above Switzerland, which is far from neutral for taxpayers whose tax residence may shift between the two countries.


These figures must nevertheless be read with care: they are maximum rates, after tax credits, which take into account neither the corporate tax paid upstream nor each State’s own relief mechanisms (partial imputation, allowances, participation regimes).


III. What it changes for shareholders and directors


Salary vs. dividends vs. retained earnings


For the director of a company subject to corporate tax, the form of remuneration is reconsidered every year. The higher flat tax, combined with the CEHR, narrows the advantage of dividends over salary or management fees for high earners. Retaining profits within a holding company, which defers personal taxation, regains appeal — subject to the constraints now attached to wealth-holding companies.


Flat tax or progressive scale?


The election for the progressive scale, which is global and irrevocable for all investment income of the year, gives access to the 40% allowance on dividends and to the partial deductibility of CSG. For households in the lower or middle brackets, it often remains more favourable than the 31.4% flat tax. The calculation must be redone every year in light of the new rate.


Timing of distributions


Crossing the CEHR thresholds depends on the reference taxable income of the year. Spreading distributions over several years, or concentrating them in a low-income year, can move the marginal rate from 35.4% to 31.4%. The averaging mechanism of Article 223 sexies for exceptional income also deserves attention.


Franco-Swiss taxpayers


For a French resident receiving Swiss-source dividends, the Swiss withholding tax (35%, reduced to 15% under the treaty) is credited against French tax; the overall rate remains the French one. Conversely, a transfer of residence to Switzerland subjects dividends to cantonal and federal tax, with partial taxation for qualifying participations. The rate gap is real, but it cannot alone justify a change of residence: exit tax, wealth and property taxation, succession and family circumstances weigh just as much.


IV. Conclusion


The headline rate is only one part of the equation. The holding structure of the shares, the applicable tax treaty, the level of reference taxable income and the rhythm of distributions do the rest. An annual review of the distribution policy, ahead of the general meeting approving the accounts, usually absorbs most of the increase.



Frequently asked questions


Dividends are investment products: the 18.6% social charges apply to dividends received from 1 January 2026. Income from assets (rental income, capital gains on securities in particular) is affected from the taxation of 2025 income.

Only if your reference taxable income exceeds €500,000 (single) or €1m (couple). Between €250,000 and €500,000 (or €500,000 and €1m for a couple), the rate is 3%. Below that, no CEHR is due and the maximum rate on dividends is 31.4%.

No. The 9.2% CSG rate is maintained by way of exception for regulated savings, life insurance and capitalisation contracts, where social charges remain at 17.2%. Dividends received within a PEA remain exempt from income tax under the usual conditions.

It depends on your marginal bracket and the composition of your investment income. The election is global: it covers all dividends, interest and capital gains of the year. A comparative simulation is essential before ticking box 2OP on the tax return.

A holding company defers personal taxation as long as dividends are not redistributed, thanks to the parent-subsidiary regime. It does not erase the tax: the flat tax and, where applicable, the CEHR apply when profits are distributed to the individual shareholder. Wealth-holding companies are also under increased scrutiny from the legislator and the tax authorities.

Switzerland withholds 35%, reduced to 15% under the France–Switzerland tax treaty on request. The French resident declares the gross dividend in France, where the flat tax (31.4%) or the progressive scale applies, and the 15% Swiss withholding is credited against French tax.


Sources: Tax Foundation, “Dividend Tax Rates in Europe”, March 2026 (OECD, PwC); Law no. 2025-1403 of 30 December 2025 (Social Security Financing Act for 2026); Articles 200 A and 223 sexies of the French Tax Code (CGI); Articles L. 136-6 and L. 136-7 of the French Social Security Code.


Eve d'Onorio di Méo

Avocat Spécialiste en Droit Fiscal

Barreau de Marseille et Genève (Avocat UE/AELE)

 
 
 

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