Trading in a company subject to corporate income tax (IS) — rates, parent-subsidiary regime & participating interests

The standard IS rate is 25 %. A reduced rate of 15 % applies to the profit tranche up to 42 500 €, subject to the following cumulative conditions: pre-tax revenue below 10 M€, fully paid-up share capital, and capital held at least 75 % by natural persons (or by a company that itself meets this criterion). Above 42 500 € of profit, the 25 % rate applies.

No. The flat-rate withholding tax (PFU, "flat tax") is reserved for individuals. In a company subject to IS, current trading gains (securities, derivatives, crypto-assets recorded on the balance sheet) are included in the IS taxable result and taxed at 15 % / 25 % depending on the tranche — not at the PFU rate.

Rarely. The long-term capital gains regime for participating interests (titres de participation) held for at least 2 years exempts the capital gain, but adds back an expenses add-back (quote-part de frais et charges) of 12 % of the gross gain, taxed at the standard rate — resulting in an effective charge of approximately 3 % (BOI-IS-BASE-20-20-10-20). This regime applies only to genuine participating interests (strategic and durable holdings), not an ordinary trading portfolio, which qualifies as investment securities (titres de placement) and remains taxed within the ordinary IS result.

Dividends paid by a subsidiary to the parent company are 95 % exempt: only an expenses add-back of 5 % is included in the taxable result. Main conditions: holding of at least 5 % of the share capital and voting rights and a commitment to retain the shares for 2 years. This regime avoids the economic double taxation of dividends within a group.

No. An SCI (société civile immobilière) is a real-estate civil company — designed for holding and managing real property, not for trading securities. To run a trading activity, an SAS or SARL subject to IS is the appropriate structure in practice. Do not confuse the two: using an SCI for financial instruments is inappropriate both legally and from a tax perspective.

It depends on your objective. A company subject to IS allows gains to be retained and reinvested at the IS rate of 15 % / 25 % as long as they are not distributed (deferral effect). But upon distribution to shareholders, the dividend is then subject to the PFU (30 % / 31,4 %): this creates double taxation (IS then personal tax). For an individual who withdraws their gains each year, the immediate PFU on a personal securities account is often simpler — and sometimes less burdensome overall. This should be assessed case by case with an accountant (expert-comptable).