The French Finance Act for 2025 adopted in February has drastically modified the tax and social security regimes applicable to gains derived from what is commonly referred to as "management packages".
This reform was officially aimed both at securing and at improving these regimes, following decades of litigation especially -albeit not exclusively- in the context of LBO transactions, most recently marked by three decisions held by the French highest administrative Court (CE, July 13, 2021, no. 435452, 428506 and 437498).
This new regime, however, raises a number of technical issues, some of which are currently under discussion with Bercy, which comments will be carefully scrutinised by all practitioners.
In the meantime, this webinar proposes to explain the historical and technical background that led to the 2021 decisions or the French Finance Act for 2025, to describe the new regime created by this Act and its advantages, and finally to explore its difficulties and pitfalls with a view to assisting practitioners in understanding and managing the existing and future "management packages" they will encounter.
