CDHR: the 20% minimum tax, and the year you leave or arrive

20% of reference income, less the tax already paid

The contribution is not a marginal 20% rate above EUR 250,000. As soon as reference income exceeds the threshold, the statute compares two amounts (art. 224, III): 20% of the whole reference income; and the sum of income tax, the exceptional contribution on high incomes (art. 223 sexies) and flat-rate withholdings, increased by EUR 1,500 per dependant and EUR 12,500 for joint taxation. The contribution is the difference, when positive. A household already bearing more than 20% owes nothing.

The tax authorities summarise the formula as: CDHR = [(reference income × 20%) − relief] − [income tax + exceptional contribution + flat-rate withholdings + family increases].

• Thresholds. Reference income above EUR 250,000 for a single, widowed, separated or divorced taxpayer, and above EUR 500,000 for joint taxation (art. 224, I).
• Relief. Where reference income is EUR 330,000 or less (EUR 660,000 for a couple), the first term is reduced to 82.5% of the difference between the income and EUR 250,000 (EUR 500,000 for a couple) (art. 224, V). For a single taxpayer with EUR 300,000 of reference income, the first term is EUR 41,250 (82.5% of EUR 50,000) instead of EUR 60,000. At EUR 330,000 both computations meet at EUR 66,000.
• Taxes taken into account. Income tax is increased by the benefit of certain tax reductions and credits, up to the tax due, and reduced by the tax on certain income taxed at a reduced rate; the lists are in paragraph IV and in BOI-IR-CDHR-10.
• Duration. The contribution applies from the taxation of 2025 income until the taxation of income for the year in which the bill on the outturn of management and approval of the accounts, tabled under article 46 of the Budget Organic Law, shows a general-budget deficit below 3% of GDP (BOI-IR-CDHR, para. 10). The rules introduced by the 2026 Finance Act, including V bis, apply from 2026 income.

The tax authorities' example (BOI-IR-CDHR-10, para. 380): a married couple with one dependent child and reference income of EUR 740,000 has a first term of EUR 148,000 (20%). Its income tax, exceptional contribution and family increases add up to EUR 116,926. The CDHR is EUR 31,074.

Reference income: what is in, what is out

Reference income is the reference tax income of article 1417, IV, 1° of the French Tax Code, without the income-averaging quotient of article 163-0 A, reduced by certain items (art. 224, II). Exceptional income therefore counts in full unless the regime described below applies.

• Excluded from the base: the allowances of point a bis of article 1417, IV, 1° (other than those of 1 ter and 1 quater of article 150-0 D), the exempt profits of point b of the same 1°, income exempt under article 155 B (inbound executives), net income under article 238 and income under article 93 quater actually taxed at 10%, gains under article 150-0 B ter whose deferral expires, and income exempt under a tax treaty.
• Non-residents. Taxpayers resident outside France are not liable, even if they receive French-source income. So-called Schumacker non-residents are within the scope, on their French-source income only (BOI-IR-CDHR-10, para. 20).
• Tax treaties. The contribution applies subject to tax treaties. Income exempt in France under a treaty, including income counted for the effective rate, is exempt from the CDHR (BOI-IR-CDHR-10, para. 180).
• Marriage, divorce, death. A change of marital status during the year follows the income tax rules (BOI-IR-CDHR-10, paras. 200 to 230).

The year of departure or arrival: paragraph V bis of article 224

A household leaving France during the year does not escape the contribution on the day it goes. Paragraph V bis, A, provides that taxpayers resident in France who transfer their residence abroad are liable for the year of their departure, on the income they received that year up to the departure date, on industrial and commercial profits made since the end of the last taxed financial year, and on all income acquired without having been received before the departure. The taxes deducted from the first term are determined on those same income items.

Paragraph V bis, B, covers arrival: taxpayers previously resident abroad who transfer their residence to France are liable for the year in which they establish their home in France, on income whose taxation results from that establishment, from the day it takes place.

• Timing. These rules apply from the taxation of 2026 income (BOI-IR-CDHR-10, paras. 60 and 70). For 2025 income, a taxpayer treated as resident in France at 31 December 2025, the date of the taxable event, is within the scope.
• What the BOFiP adds. For departures, the BOFiP (para. 60) also includes non-commercial and agricultural profits made since the end of the last taxed financial year and income whose taxation was deferred; the statute mentions industrial and commercial profits and income acquired without having been received. The firm takes the more cautious reading.
• After departure. Once tax residence is effectively transferred abroad, the household is no longer liable in later years, provided the residence is genuinely established under article 4 B and the applicable treaty. Income received after the departure date is outside V bis, A.
• What this requires. A move to Geneva, or a return from Geneva, is planned around the calendar of income: dividends, variable pay, holding company distributions, disposals. A distribution you can dispose of before the departure date is in the base for the year of departure; one you can dispose of afterwards is not in principle, unless the income was acquired before departure without being at your disposal, which V bis, A also covers, and without prejudice to exit tax (moving to Switzerland) and treaty taxation.
• Inbound executives. Income and pay exempt under article 155 B are excluded from reference income (art. 224, II, 3°); see moving back to France.

Exceptional income counts for a quarter

Income that by its nature cannot be received every year and whose amount exceeds the average of the net income on which the taxpayer was taxed in the last three years is counted for one quarter of its amount in reference income; the related income tax and exceptional contribution are also counted for one quarter (art. 224, II, ninth paragraph, and IV).

• Two cumulative conditions. Exceptional by nature (outside the normal course of the activity) and by amount (above the three-year average). A capital gain on shares can qualify when it results from a one-off transaction; it does not if the taxpayer regularly carries out similar transactions (BOI-IR-CDHR-20, paras. 20 to 60).
• An option to exercise. The regime is claimed by completing the relevant boxes of supplementary return no. 2042-C (BOI-IR-CDHR-30, para. 1). If the authorities challenge the characterisation, they proceed by notice of reassessment.
• Change of family status. The comparison with the previous three years is adjusted on marriage, civil partnership, divorce, separation or death (BOI-IR-CDHR-20, paras. 80 to 110).

Filing, advance payment and audit

• Filing. The CDHR is declared like income tax; the base is established by the authorities the year after the income is received, from the overall return (BOI-IR-CDHR-30, para. 1).
• Advance payment. An advance of 95% of the estimated contribution is paid between 1 and 15 December of the tax year, from 2025 income. It is outside the withholding-at-source system. A 20% surcharge applies for non-payment or late payment, or if the advance is more than 20% below 95% of the contribution due (BOI-IR-CDHR-30, paras. 40 to 110).
• Audit. Income tax audit and litigation rules apply, with the limitation period of article L. 169 of the Tax Procedure Code, which in principle ends at the end of the third year following the year of taxation (BOI-IR-CDHR-30, paras. 90 and 100).
• Calculator. The tax authorities provide a calculation tool on impots.gouv.fr, under Particulier (BOI-IR-CDHR-30, para. 70).

No published decision on article 224 to date

The contribution is recent: it applies from 2025 income. Our search of 12 October 2026 in the Légifrance databases of the Conseil d'État and the administrative courts, in those of the Conseil constitutionnel and in Judilibre returns no decision applying or interpreting article 224. The Conseil constitutionnel ruled on the 2025 Finance Act on 13 February 2025 (decision no. 2025-874 DC) without examining its article 10, which creates the contribution: the absence of a strike-down is not a finding of conformity on that point. CDHR litigation will follow income tax litigation; the firm updates this page as soon as a decision is handed down.