Doctor Tax Regime in France 2026: BNC, SELARL, Optimisation

Updated 12 May 2026. The tax regime of a private doctor practising in Paris is not reduced to a choice between a 2042-C-PRO return and a 2035 tax bundle. It combines an income status (BNC or company manager's remuneration), a sub-regime (micro or actual), a contractual sector (1, 2 or 3) and, increasingly since the Law of 31 December 1990, an option to practise through a société d'exercice libéral (SELARL, SELAS, SCP). Each of these parameters changes the taxable base, the marginal rate, CARMF and URSSAF PAM contributions, and the future sale value of the practice. At Cabinet Hayot Expertise, we support these trade-offs at installation, at year 5 (post-equipment amortisation), and at age 55 (sale preparation). This article maps the tax landscape applicable on 12 May 2026, without overlapping with our dedicated articles on medical VAT and invoicing, sector grants and exemptions or critical accounting mistakes.

The liberal practice of a regulated medical profession falls by default, on the tax side, within the category of bénéfices non commerciaux (BNC — non-commercial profits) defined in Article 92 of the French General Tax Code (CGI). The doctor is taxed personally on income tax on the net result generated by their activity, after deduction of eligible professional expenses (Article 93 CGI). On the tax side, no distinction is made between a general practitioner, a specialist, a radiologist, a surgeon-dentist or an anaesthetist: all fall under BNC as long as they practise in their own name.

Three variables nevertheless structure the actual tax burden: the sub-regime (micro-BNC or actual declaration), the contractual sector (1, 2 or 3), and the form of practice (individual or through an SEL). These variables are independent but interact strongly: a sector-2 doctor in SELARL does not bear the same tax and social burden as a sector-1 doctor under BNC actual declaration, even at equivalent revenue.

The micro-BNC regime (Article 102 ter CGI)#

Micro-BNC applies as of right to doctors whose annual revenue excluding VAT does not exceed the threshold set in Article 102 ter CGI — set at €83,600 for the 2026-2028 period. Taxable profit is calculated forfait by applying a 34% representative expense allowance to gross revenue. The return is filed directly on form 2042-C-PRO, lines 5HQ/5HP/5HX depending on the situation.

Micro-BNC offers real administrative simplicity (no 2035 bundle, simplified accounting) but becomes highly unfavourable as soon as actual expenses exceed 34% of revenue. This is almost always the case for an established doctor in Paris: office rent, secretarial services, imaging equipment, diagnostic leasing, professional liability insurance, college fees, mandatory continuing education. The economic switch threshold is usually reached as early as the second year of installation.

Actual declaration (Article 96 CGI)#

Beyond the micro threshold, or by express option, the doctor falls under the actual regime called "actual declaration". They file each year the 2035 tax bundle (and its 2035-A, 2035-B, 2035-E annexes for CVAE where applicable), accompanied by the OG (approved management body) table if the doctor has joined an AGA — joining an AGA is no longer necessary to avoid the 25% surcharge, definitively abolished by the 2023 finance law.

Actual declaration requires the keeping of a revenue and expense ledger (Article 99 CGI), a general ledger, and a register of fixed assets. Bookkeeping can be performed using the cash basis method (receipts-disbursements) or accrual basis (acquired receivables - certain liabilities). The cash basis method is the dominant practice among private doctors and offers a more readable cash management.

When to opt for actual declaration below the threshold#

A doctor whose revenue is below the micro-BNC threshold may opt for actual declaration if their actual expenses exceed 34% of revenue. The option is valid for one year, tacitly renewable. For a young doctor installed in year 1 or 2, with heavy initial investment (patient base buy-out, equipment), actual declaration allows recording a BNC loss deductible from the household's overall taxable income (Article 156 CGI), a powerful optimisation lever at installation.

Sector 1 (conventionné)#

A sector-1 doctor applies Social Security tariffs, receives ROSP (public health objectives remuneration), benefits from the médecin traitant lump sum, and enjoys favourable CARMF caps: URSSAF coverage of part of the health insurance contributions. The taxable base equals gross revenue less expenses. The social burden, in practice, stands at around 30 to 35% of net BNC for a median sector-1 doctor.

Sector 2 (free fees)#

Sector 2 allows fee overcharges, subject to tact and moderation. Revenue is higher, but the doctor loses the benefit of URSSAF coverage of health insurance contributions and sees CARMF and ASV contributions calculated on a higher net income. The total social burden (URSSAF PAM + CARMF + ASV + CSG/CRDS) typically reaches 40 to 50% of net BNC, neutralising part of the revenue gain if the overcharge differential is not significant.

Sector 3 (non-conventionné)#

Sector 3, marginal (psychiatrists, some specialists), practises outside the convention: fully free fees, no ROSP, no URSSAF coverage, and inflated URSSAF PAM contributions. From a tax perspective, BNC is calculated identically, but the economic trade-off almost systematically tilts towards switching to a SEL (SELARL/SELAS) to neutralise the over-contribution and smooth remuneration.

The Law of 31 December 1990 and its forms#

Law No. 90-1258 of 31 December 1990 created sociétés d'exercice libéral (SEL), enabling regulated liberal professions to practise through a commercial company subject to corporate income tax. This law was substantially amended by Ordinance No. 2023-77 of 8 February 2023 (gradual entry into force in 2024-2025), tightening capital ownership rules — a point to verify precisely at the time of the trade-off.

Three forms coexist in 2026:

• SELARL (limited liability liberal practice company): the most common, modelled on the SARL. The majority manager falls under the TNS regime (self-employed) with deductible Madelin contributions.
• SELAS (simplified joint-stock liberal practice company): modelled on the SAS, the president is treated as a salaried executive, does not receive unemployment, but benefits from the general Social Security regime.
• SCP (professional civil partnership): an older form, fiscally transparent (IR unless IS option), rarely used in new incorporations.

Switch to corporate tax: Article 209 CGI and 2026 rates#

Election for corporate income tax — automatic in SELARL/SELAS, optional in SCP — subjects profit to corporate income tax. In 2026, the standard rate is 25% above €42,500 of taxable profit. The reduced rate of 15% applies to the first €42,500, subject to three cumulative conditions: turnover below €10M, fully paid-up share capital, and ownership greater than 75% by individuals (or by a company itself meeting the criterion).

The associated doctor then becomes employee or manager of their company. They receive a remuneration (deductible from profit) and possibly dividends (subject to the 30% flat tax or, on option, to the progressive scale with a 40% allowance). The remuneration/dividends trade-off is detailed in our article on executive compensation optimisation and the 2026 dividends regime.

Tax and wealth advantages of the SEL#

The SEL switch unlocks several levers: capitalisation of undistributed profit taxed at 25% (vs a personal marginal rate that can reach 45%), smoothing of remuneration to optimise tax brackets, Madelin retirement deduction (TNS) or URSSAF contributions (assimilated employee), and the ability to acquire an operating SCI holding the practice premises through a holding company.

Drawbacks and watch points#

Article L131-6 III of the Social Security Code provides that dividends paid to a SELARL majority manager, for the fraction exceeding 10% of share capital, share premiums and current account balances, are subject to TNS contributions (~45% social charges). This rule partly neutralises the dividend optimisation for SELARLs and frequently leads to preferring the SELAS in recent trade-offs.

Added to this: higher annual accounting and legal operating cost (general meeting, management reports, filing of accounts with the registry), regulated agreements to comply with (Article L227-10 of the Commercial Code for the SAS/SELAS), and the risk of the IS election being challenged in case of statutory irregularity.

Article 151 septies CGI#

Article 151 septies CGI fully exempts the capital gain on the sale of a medical practice operated for more than 5 years when the average revenue excluding VAT of the two preceding financial years is below €90,000 (full exemption) or between €90,000 and €126,000 (degressive exemption). The threshold targets "small practices" and mainly benefits rural doctors or replacement activities.

Article 151 septies B CGI: holding period allowance#

For long-term professional real estate capital gains, Article 151 septies B applies a 10% allowance per year of holding beyond the fifth, leading to a full exemption after 15 years. Particularly useful for practice premises held directly or through an income-tax SCI.

Article 238 quindecies CGI: full practice sale#

Article 238 quindecies CGI fully exempts the capital gain on the full sale of a liberal professional activity when the value of the transferred elements is below €500,000. The exemption is degressive up to €1,000,000. This is the flagship mechanism for practice sales in Paris, where the patient base and equipment frequently reach these amounts.

Article 150-0 D ter CGI: €500,000 retiring director allowance#

For the sale of SELARL/SELAS shares held for more than 8 years, Article 150-0 D ter CGI provides a fixed €500,000 allowance on the capital gain, subject to conditions (cessation of functions, retirement within two years). The mechanism was extended until 31 December 2031 by the 2024 Finance Law (to be confirmed in the 2026 Finance Law). It is the major tax argument in favour of switching to an SEL in mid-career.

Family transmission and Dutreil#

Article 41 CGI allows the spreading of capital gains in the event of a free transmission (succession or donation) with continuation of activity by the successor. The Dutreil pact (Article 787 B CGI for company shares, 787 C for the individual enterprise) adds a 75% allowance on free transfer duties, applicable to SELARL/SELAS under collective and individual conservation commitment conditions. This subject falls within a global wealth strategy covered in our article on holding companies and tax optimisation.

The CARMF / URSSAF PAM / ASV / CSG-CRDS quadriptych#

The doctor in BNC or TNS manager of a SELARL pays annually:

• CARMF basic and supplementary retirement: about 10 to 15% of net BNC depending on brackets.
• URSSAF PAM health-maternity-family allowances: about 10% of net BNC for sector 1, more for sectors 2 and 3.
• ASV Additional Old-Age Allowances: 3 to 4% of net BNC (partial CPAM coverage for sector 1).
• CSG/CRDS: 9.7% on non-salaried activity income.

Approximate total: 30 to 40% of net BNC for a median sector-1 doctor, 40 to 50% for a sector-2 or sector-3 doctor. The pension reform for liberal professions enacted by the Law of 14 April 2023 takes effect in 2026 with a gradual increase in contributions and retirement age — to monitor in CARMF communications.

2026 Madelin retirement and protection caps#

Under the BNC or TNS regime, the doctor can deduct:

• Madelin retirement: 10% of taxable profit capped at 8 PASS + 15% of the share of profit between 1 and 8 PASS. Indicative 2026 maximum cap: around €85,000 (to be recalculated with the published 2026 PASS).
• Madelin protection and health insurance: 3.75% of profit + 7% of PASS, capped. Indicative 2026 maximum: around €9,000.
• Madelin unemployment: 1.875% of profit + 2.5% of PASS.

These deductions are calculated on the BNC taxable profit base. For a doctor in SELARL as majority manager, the base is the net TNS remuneration. For a SELAS president, the Madelin regime does not apply (general regime).

The tax trade-off of a private doctor in Paris plays out, in 90% of files, in three stages. At installation (years 1-2), actual declaration is almost always preferable to micro-BNC to activate the loss deductible from overall taxable income. Mid-career (years 5-15), the switch to SELARL or SELAS becomes relevant as soon as net BNC sustainably exceeds €120,000 to €150,000, with a SELARL/SELAS trade-off depending on the wealth project (Madelin TNS vs general regime) and the distribution strategy. Before sale (years 50-60), the combination of Article 238 quindecies CGI and Article 150-0 D ter CGI structures the optimal exit, arbitrating between sale of the practice (BNC) and sale of the shares (SEL).

No decision is made without simulating net flows over five years, social and tax charges aggregated. For doctors based in Paris, we offer this fiscal and wealth audit through our Paris 8 accounting team or our outsourced CFO service for liberal practices. Our approach also covers medical practice financial KPIs, addressed in our dedicated analysis.