2025 Budget Act – News
Changes to the Tax Treatment of Management Packages
Following the enactment of the 2025 Finance Act and the introduction of legislation regarding the taxation of management packages, various institutions have initiated discussions with government authorities, particularly the Tax Legislation Directorate. On the managers’ side, forces are uniting withinALESI.
Our firm is actively involved in these discussions, in our capacity as experts, in the best interests of our clients as well as all executives, employees, and their companies.
Given the importance of the issue, the press quickly picked up on it, and progress has been made through ongoing discussions. A revision of certain aspects of the 2025 Finance Act—in particular regarding the possibility of deferring taxes on reinvested amounts classified as salaries during an exit—will be prepared for retroactive inclusion in the 2025 Finance Act in the next draft bill, which will be discussed in the fall.
In the near term, clarifications regarding the applicable rules—which will be enforceable against the tax authorities in the event of an audit—will be published as early as May, initially in the form of a draft open for public comment.
However, we are working with the other stakeholders involved, alongside the leadership, to ensure that useful clarifications are provided as soon as this draft is made publicly available.
We remain available to answer any questions you may have on this subject, and if you encounter any specific difficulties in interpreting or applying the new legal framework, please let us know immediately of any situation that you feel would be worth bringing to the attention of the departments within the Tax Legislation Directorate so that a response as constructive as possible can be provided.
Firm Contacts
Jérôme Commerçon
Tel: +33 (0) 1 83 92 38 38
jcommercon@scottopartners.com
Emilie Renaud
Phone: +33 (0) 1 83 92 38 38
erenaud@scottopartners.com




