REFERENCE GUIDE
Tax practice · Real estate and furnished lettings

The taxation of para-hotel services: the complete guide

Para-hotel services refer to the letting of furnished premises combined with services close to those of the hotel trade. They differ from ordinary furnished letting in one central respect: liability to VAT. An activity qualifies as para-hotel where the lessor provides, under conditions similar to the hotel trade, at least three of the four reference services (breakfast, regular cleaning of the premises, supply of household linen, reception of guests), within the meaning of article 261 D, 4°-b of the French Tax Code. This characterisation then governs the VAT regime, the taxation of income (BIC, LMNP/LMP, depreciation), social security contributions and the CFE. This guide brings these dimensions together and links the firm's entire cluster.

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Para-hotel services: the services test

Under French domestic law, the letting of furnished residential premises is exempt from VAT pursuant to article 261 D, 4° of the French Tax Code. Paragraph b of that provision lays down a decisive exception: the exemption falls away where the lessor provides, in addition to accommodation, para-hotel services under conditions similar to those of hotel-type accommodation establishments. It is this exception that defines para-hotel services and subjects them to VAT.

The test rests on four reference services: breakfast, regular cleaning of the premises, supply of household linen and reception of guests, even where not personalised. Since the alignment carried out by the Finance Act for 2024, article 261 D, 4°-b itself requires the provision of furnished premises combined with at least three of these four services, the accommodation being moreover offered for a period not exceeding thirty nights. The courts assess whether these services are genuine and effectively supplied, beyond their formal mention in a contract.

The framework was reshaped by the decision of the Conseil d'État of 5 July 2023 (no. 471877), which held part of article 261 D, 4°-b incompatible with the VAT Directive, followed by a legislative alignment of the provision. The para-hotel characterisation triggers a chain of consequences: VAT regime (liability, right to deduct, election), taxation of income as BIC under the LMNP or LMP regime, social security contributions and the business property levy (CFE). The firm takes on a limited number of cases in order to guarantee the direct involvement of its partners, and assesses the relevance of its intervention before any engagement.

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The four dimensions of para-hotel taxation

01

Para-hotel characterisation

Characterisation is the starting point of the whole regime. It rests on the effective supply of services under conditions similar to the hotel trade, assessed service by service.

  • The four-services test (breakfast, regular cleaning, supply of linen, reception of guests) and the threshold of three services out of four: see our dedicated analysis of the para-hotel characterisation of services
  • The boundary with ordinary furnished letting exempt from VAT (French Tax Code art. 261 D, 4°), detailed on our page on the taxation of furnished lettings
  • The assessment of whether the services are genuine and similar to the hotel trade, beyond the contractual clauses
  • The interaction with the letting of tangible movable property where equipment distinct from the accommodation is made available: see VAT on lettings of tangible movable property
02

Para-hotel VAT

The para-hotel characterisation takes the activity out of the exemption and subjects it to VAT, with the taxation of receipts, the right to deduct on expenditure and, where applicable, the election.

03

Income tax: BIC, LMNP and LMP

Para-hotel income is taxed in the category of industrial and commercial profits, with the interplay of depreciation and the distinction between non-professional and professional lessors.

  • Taxation as BIC, the choice between the micro-BIC and the actual-profit regime, and the deduction of depreciation of the property and furniture under the actual regime: see para-hotel services, LMNP, LMP and income tax
  • The LMNP / LMP distinction and the regime of article 155, IV of the French Tax Code (receipts threshold of 23,000 euros and predominance of these receipts in the tax household's income)
  • The treatment of losses and their differentiated offsetting depending on whether the activity is professional or not
  • The place of the activity within the taxpayer's overall real-estate taxation
04

Social security contributions and CFE

Para-hotel services constitute an activity of a commercial nature: above a receipts threshold, they trigger social security affiliation, as well as liability to the business property levy (CFE).

  • Social security affiliation in respect of a para-hotel activity and the receipts threshold of 23,000 euros (CSS art. L. 611-1): see social security contributions on para-hotel services
  • The distinction between the self-employed regime and the general regime depending on the nature and intensity of the services supplied
  • Liability to the business property levy (CFE) in respect of an activity carried on on a regular basis
  • The interaction of social levies on investment income with the contributions due in respect of the activity
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The firm's analyses

All the articles in the para-hotel cluster, from characterisation to VAT, income tax and social security contributions.

Characterisation

Para-hotel characterisation: the services test

The four-services test (breakfast, regular cleaning, supply of linen, reception) and the threshold of three services out of four for falling within the para-hotel field.

2026 Lire l'article
VAT · BOFiP

Para-hotel VAT: the BOFiP reading

Liability to VAT, right to deduct and conditions of article 261 D, 4°-b, as clarified by the administrative doctrine.

2026 Lire l'article
Conseil d'État

VAT and furnished lettings: the ruling of 12 November 2025

The Conseil d'État decision of 12 November 2025 tightens the conditions of the para-hotel regime and narrows the assessment of the reference services.

November 2025 Lire l'article
VAT · Review

Para-hotel VAT: 2026 review after decision no. 498267

State of the para-hotel regime following decision no. 498267: criteria applied, practical consequences for lessors.

2026 Lire l'article
Income tax

Para-hotel services, LMNP, LMP and income tax

Taxation as BIC, depreciation of the property and furniture under the actual regime, LMNP/LMP distinction and the regime of article 155, IV of the French Tax Code.

2026 Lire l'article
Social security contributions

Social security contributions on para-hotel services

Social security affiliation above the receipts threshold of 23,000 euros (CSS art. L. 611-1), applicable regime and interaction with social levies.

2026 Lire l'article
Furnished lettings

Taxation of furnished lettings

The regime of furnished lettings exempt from VAT (French Tax Code art. 261 D, 4°), an essential benchmark for delimiting para-hotel services.

2026 Lire l'article
Hotel trade

Hotel VAT

The VAT regime specific to hotel establishments, the reference against which para-hotel services are compared.

2026 Lire l'article
Short-term rentals

Airbnb and VAT

VAT treatment of short-term rentals and the boundary with para-hotel activity depending on the services offered.

2026 Lire l'article
Hotel trade

VAT and no-shows in the hotel trade

VAT regime of no-show compensation and unhonoured bookings in the accommodation sector.

2026 Lire l'article
VAT · Movable property

VAT on lettings of tangible movable property

VAT regime of the provision of equipment and tangible movable property, to be distinguished from para-hotel accommodation.

2026 Lire l'article
Real estate

Real-estate taxation

Overview of the real-estate taxation within which the taxpayer's para-hotel activity fits.

2026 Lire l'article
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Frequently asked questions

What are para-hotel services for tax purposes?

Para-hotel services consist of the letting of furnished premises combined with services supplied under conditions similar to those of the hotel trade. Whereas furnished letting is in principle exempt from VAT (article 261 D, 4° of the French Tax Code), para-hotel activity falls within the exception of article 261 D, 4°-b and is subject to VAT. The decisive criterion is not the nature of the property, but the existence of genuine para-hotel services.

What are the four reference para-hotel services?

The four reference services are: breakfast, regular cleaning of the premises, supply of household linen and reception of guests, even where not personalised. Since the Finance Act for 2024, article 261 D, 4°-b of the French Tax Code provides that the provision of furnished premises combined with at least three of these four services, for a period not exceeding thirty nights, brings the activity within the para-hotel field subject to VAT.

Are para-hotel services subject to VAT?

Yes. Once the activity is characterised as para-hotel, it falls outside the exemption of article 261 D, 4° of the French Tax Code and becomes subject to VAT. In return, this liability opens a right to deduct the VAT borne on investments (acquisition, works, furniture) and on operating expenses. The precise regime, together with the scope of the Conseil d'État decision of 12 November 2025, is detailed in our analyses para-hotel VAT and the BOFiP and the ruling of 12 November 2025.

What is the scope of the Conseil d'État decision of 5 July 2023?

In its decision of 5 July 2023 (no. 471877), the Conseil d'État held part of article 261 D, 4°-b of the French Tax Code incompatible with the VAT Directive, insofar as it rested on cumulative conditions that were too rigid. That decision led to a legislative alignment of the provision, which refocuses the analysis on the genuine supply of services under conditions similar to the hotel trade. Subsequent case law, including the decision of 12 November 2025, has clarified these conditions.

How is para-hotel income taxed?

Para-hotel income falls within the category of industrial and commercial profits (BIC). The lessor may opt for the actual-profit regime and deduct expenses, as well as the depreciation of the building and furniture, which significantly reduces taxable income. Depending on the level of receipts and the conditions of article 155, IV of the French Tax Code, the activity is carried on as a non-professional lessor (LMNP) or a professional lessor (LMP), which changes the treatment of losses in particular. See our page para-hotel services, LMNP, LMP and income tax.

What is the difference between ordinary furnished letting and para-hotel services?

Ordinary furnished letting is limited to the provision of an equipped dwelling and remains exempt from VAT (French Tax Code art. 261 D, 4°). Para-hotel services add services (breakfast, cleaning, linen, reception) under conditions close to the hotel trade, which brings the activity within the scope of VAT and entails consequences in terms of social security and CFE. The dividing line therefore lies in the nature and genuineness of the services, detailed on our pages taxation of furnished lettings and para-hotel characterisation.

Do para-hotel services trigger affiliation for social security contributions?

Yes, above a receipts threshold. As para-hotel services constitute an activity of a commercial nature, they trigger social security affiliation where annual receipts exceed 23,000 euros, pursuant to article L. 611-1 of the French Social Security Code. The applicable regime (self-employed or general regime) depends on the nature and intensity of the services supplied. See our analysis of social security contributions on para-hotel services.

Is para-hotel activity subject to the CFE?

Yes. Para-hotel services constitute a professional activity carried on on a regular basis: they are in principle subject to the business property levy (CFE), like any commercial activity. This levy comes on top of the consequences in terms of VAT, income tax and social security contributions, which justifies an overall analysis of the project before it is set up.

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