Zucman Tax: Where Do We Stand Legally?

The Zucman tax, inspired by the work of economist Gabriel Zucman, aims to establish a 2% minimum tax on net wealth exceeding 100 million euros. It would affect a limited population, estimated at between 1,800 and 4,000 households—around 0.01% of French taxpayers—and is expected to generate between 15 and 25 billion euros annually.

Adopted in a first reading by the National Assembly on February 20, 2025, the proposal was later rejected by the Senate on June 12, 2025. Supporters highlight it as a tool for tax justice, designed to limit optimization strategies that allow the wealthiest to significantly reduce their contributions. Opponents, however, fear a massive tax exodus, describe it as potentially confiscatory, and warn of risks to France’s economic attractiveness.

The bill nevertheless included some safeguards, such as the exclusion of professional assets related to SMEs or artisans, to avoid hindering economic activity. It also introduced a specific rule allowing the taxation of wealthy individuals’ assets for up to five years after leaving France, in order to curb tax avoidance.

From a legal perspective, the measure raises significant constitutional concerns, particularly regarding property rights and the principle of equality before taxation. The Constitutional Council could intervene if the tax were deemed excessive. In light of these uncertainties, the government is considering more moderate alternatives, such as a 0.5% minimum differential tax on wealth, excluding professional assets.

The Zucman tax thus illustrates a recurring dilemma in tax law: finding the right balance between combating inequality and maintaining economic competitiveness. For now, the measure remains on hold, its future depending as much on political choices as on its legal feasibility.