LMNP or SCI: which tax regime to let furnished in France in 2026?
Direct LMNP, a corporate-tax SCI or a SARL de famille: letting furnished property through an income-tax SCI (société civile immobilière) forces a switch to corporation tax. A clear comparison, the resale tax implications, and the impact of the 2025 capital gains reform — so you can choose the right structure before you sign.
This topic is part of our service
LMNP accountant in France | Real regime & depreciationExpert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
The question comes up constantly: should a furnished property be bought as an LMNP (loueur en meublé non professionnel — a non-professional furnished landlord status under income tax) or through an SCI (société civile immobilière — a civil property company)? Framed that way, it compares two things that are not of the same nature. LMNP is an individual tax status for carrying on furnished rental activity; an SCI is a property-holding vehicle. The real decision turns on the objective of the project and the tax consequences during ownership and at resale.
One point must be stated upfront, because it is widely misunderstood. An income-tax SCI cannot let furnished property on a habitual basis without switching to corporation tax: furnished letting is a commercial activity. That switch changes everything, especially the taxation on resale.
Direct answer. To let furnished, three frameworks exist: direct LMNP ownership (BIC — industrial and commercial profits — micro or réel regime), an SCI taxed at corporate level (furnished letting takes the SCI out of income tax) and a SARL de famille (a family limited company that does allow furnished letting under income tax). A standard income-tax SCI is not suited to habitual furnished letting. The choice depends on your objective: personal yield, multi-owner holding or transmission.
Can an SCI let furnished property?#
Yes, but with a major consequence. When a civil company lets furnished premises on a habitual basis, it is treated as carrying on a commercial activity and becomes subject to corporation tax (IS) under article 206 of the French Tax Code (CGI). A family SCI set up under income tax for its flexibility therefore loses its tax transparency as soon as it lets furnished to any significant degree.
An administrative tolerance exists: if the commercial (furnished) receipts stay below 10% of the SCI's total receipts, the automatic switch to corporation tax is not triggered. Beyond that threshold, the switch applies. In other words, the commonly cited idea of "LMNP through an SCI" really means an SCI taxed at corporate level — or a SARL de famille, which is the structure suited to letting furnished while remaining under income tax.
The trap we see most often: a family SCI created "to keep things simple", then used to let furnished without realising it switches to corporation tax and that the resale becomes a far heavier professional capital gain.
Income-tax SCI or corporate-tax SCI to let furnished?#
The distinction is decisive. The income-tax SCI falls under property income (revenus fonciers) and suits unfurnished letting; it does not depreciate the property, and resale follows the private capital gains regime (with holding-period allowances). The corporate-tax SCI can depreciate the property, reducing taxable profit during ownership, but the gain on sale becomes a professional capital gain — with no holding-period allowance and with depreciation added back.
| Framework | Taxation of rents | Depreciation | Capital gain on resale |
|---|---|---|---|
| Direct LMNP (réel) | BIC, after expenses and depreciation | Yes | Private capital gain, but depreciation added back since 2025 |
| Income-tax SCI (unfurnished letting) | Property income | No | Private capital gain, holding-period allowances |
| Corporate-tax SCI (furnished) | Profit taxed at IS (15% then 25%) | Yes | Professional gain, no allowance, depreciation added back |
| SARL de famille (furnished) | BIC under income tax (transparent) | Yes | Private capital gain |
What is the resale tax under each structure?#
It is often at exit that the choice of structure reveals its true cost. A corporate-tax SCI that has depreciated the property generates, on resale, a professional capital gain computed on the net book value: the depreciation claimed inflates the gain taxable at corporation tax, with no holding-period allowance. Exit taxation can then be markedly heavier than for an individual.
In direct LMNP, resale follows the private capital gains regime. But since the 2025 Finance Act (loi n° 2025-127 du 14 février 2025, article 84, amending article 150 VB of the CGI), depreciation deducted under the réel regime reduces the acquisition price retained for the computation, which increases the gross gain. The gap between LMNP and a corporate-tax SCI has therefore narrowed on this point, but LMNP keeps the holding-period allowances — full income-tax exemption beyond 22 years, and full social levies exemption beyond 30 years — which the corporate route does not offer.
For the full detail of this reform, see The real LMNP 2026 reform and our LMNP tax guide.
Worked example: reselling a furnished property#
Take a property bought for €250,000 and depreciated by €50,000 over the holding period, resold for €350,000.
In a corporate-tax SCI, the professional gain is computed on net book value (€250,000 − €50,000 = €200,000), giving a €150,000 gain taxed at corporation tax, with no holding-period allowance. In LMNP under the réel regime, the private capital gain starts from an acquisition price reduced by the depreciation claimed (€200,000), giving a €150,000 gross gain — but then reduced by holding-period allowances depending on the number of years held, up to full exemption. Over a long holding period, LMNP generally remains more favourable at exit for an individual investor.
These figures illustrate the underlying logic; they do not replace a simulation on your actual file, which must factor in the financing, the applicable corporation tax rate and the planned resale horizon.
Direct LMNP, corporate-tax SCI or SARL de famille: how to choose?#
Three questions frame the decision. Are you primarily after personal yield, multi-owner holding or a transmission tool? Are you buying alone, as a couple or as a family? And do you intend to hold for the long term, transmit gradually or resell?
- An individual, yield-driven project held for the long term: direct LMNP is often the most natural framework and the most favourable at exit.
- Furnished letting with several people or a family, keeping income tax: the SARL de famille is usually more suitable than an SCI, because it allows furnished letting under income tax.
- Structured patrimonial holding, long-term capitalisation, family governance: a corporate-tax SCI can make sense, provided you accept the exit taxation.
The income-tax SCI retains its full relevance for unfurnished letting and for transmitting shares progressively, but not for habitual furnished letting. To compare SCI and SARL de famille in detail, see SARL de famille or SCI and SCI under IS or IR.
SCI, dismemberment and transmission: the real advantage of the civil company#
If your primary objective is transmission, the logic shifts. An SCI (under income tax for unfurnished letting) remains a powerful transmission tool — not for letting furnished, but for fractioning and giving shares progressively. Giving SCI shares allows you to use the €100,000 allowance per parent per child every fifteen years, and to transfer the bare ownership (nue-propriété) while retaining the usufruct — and therefore the income — until death.
Dismemberment of shares or property is a well-established lever: the value of the bare ownership transferred is discounted according to the usufructuary's age, which reduces the taxable base for gift tax. To explore this mechanism in depth, see our article on dismemberment and SCPI. But this reasoning applies to patrimonial holding and transmission — not to arbitrating the operating structure for a furnished rental. Do not confuse the two objectives.
The most common mistakes#
- Creating an income-tax SCI and then letting furnished without realising the automatic switch to corporation tax.
- Choosing a corporate-tax SCI for its annual advantage (depreciation) without quantifying the professional exit gain.
- Confusing transmission (where the SCI excels) with furnished letting (where it is poorly suited).
- Deciding on the structure after signing, when it conditions both the financing and the taxation.
- Forgetting that the SARL de famille allows furnished letting under income tax, while an SCI switches to corporation tax.
Why decide before you buy#
The holding structure influences financing, annual taxation, resale and sometimes the very feasibility of the project. Changing it later — for example converting an SCI into a structure suited to furnished letting — usually triggers tax costs: deemed cessation of activity, taxation of latent gains, rewriting the articles of association.
In our client files, the depreciated corporate-tax SCI is regularly chosen for its annual advantage, without the professional exit gain ever being quantified. It is precisely at resale that the bill becomes apparent. Better to write the objective down clearly — cash flow, capitalisation or transmission — before locking in the structure.
Compare properly over 5 to 15 years#
A sound comparison does not stop at the first-year tax figure. It must include the deposit and financing, the level of charges during ownership, the flexibility between co-owners, the tax on sale, any transmission objective and the management time you are willing to devote. It is by modelling the exit scenario that the decision becomes clear.
We can model a direct furnished purchase, a corporate-tax SCI and a SARL de famille, with the consequences over 5 to 15 years. Our dedicated support for property investors (SCI, LMNP) includes a patrimonial review and an exit simulation, and our LMNP accounting support secures the file over the long term.
Conclusion#
In 2026, the right answer depends on your objective: immediate yield, family ownership, capitalisation or transmission. An SCI letting furnished property is not an administrative variant of LMNP: it switches to corporation tax and changes the exit taxation. To let furnished under income tax with several owners, the SARL de famille is often the best answer.
Current as of 26 May 2026. This article is for information purposes only and does not replace advice tailored to your situation. For any decision, consult a chartered accountant (expert-comptable) registered with the Ordre des experts-comptables.
Frequently asked questions
Can an SCI let furnished property?
Yes, but with a major consequence. An income-tax SCI that lets furnished on a habitual basis switches to corporation tax: furnished letting is a commercial activity under article 206 of the CGI. An administrative tolerance exists if furnished receipts stay below 10% of the SCI's total receipts. Beyond that, corporation tax applies. To let furnished while staying under income tax with several owners, the SARL de famille (a family limited company) is generally more suitable than an SCI.
Should I prefer direct LMNP or an SCI?
For an individual, yield-driven project held for the long term, direct LMNP is often the most natural framework and the most favourable at exit, thanks to holding-period allowances. A corporate-tax SCI suits structured patrimonial holding, multi-owner arrangements, and long-term capitalisation — provided you accept a heavier exit tax (professional capital gain with no holding-period allowance). The choice is driven by objective and time horizon, not by the first-year tax figure alone.
What is the resale tax: corporate-tax SCI or LMNP?
In a corporate-tax SCI, resale generates a professional capital gain computed on net book value: depreciation claimed inflates the gain taxable at corporation tax, with no holding-period allowance. In LMNP, resale follows the private capital gains regime, with holding-period allowances (full income-tax exemption beyond 22 years) — even though the 2025 reform now adds back depreciation in the computation. Over a long holding period, LMNP generally remains more favourable at exit.
Does the 2025 capital gains reform change the LMNP vs SCI decision?
It narrows the gap. Since the 2025 Finance Act (loi n° 2025-127 du 14 février 2025, art. 84), depreciation deducted under the LMNP réel regime reduces the acquisition price retained for the private capital gains computation, as was already the case for the professional gain of a corporate-tax SCI. LMNP, however, retains holding-period allowances that the corporate route does not offer. The structure is therefore still chosen according to objective and time horizon, not on this criterion alone.
Should the structure be chosen before buying?
Yes — that is the best moment to decide. The holding structure influences financing, annual taxation, resale and sometimes the very feasibility of the project. Changing it afterwards — converting an SCI, switching regime — usually triggers tax costs: deemed cessation of activity, taxation of latent gains, rewriting the articles of association. Better to define the objective (yield, capitalisation, transmission) before locking in the legal framework.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- impots.gouv.fr — Les locations meublées
- Légifrance — Article 206 du CGI (assujettissement à l'IS de la SCI)
- impots.gouv.fr — Plus-value de cession d'un bien loué meublé (réforme 2025)
- Loi n° 2025-127 du 14 février 2025, article 84 (réintégration des amortissements LMNP) — Légifrance
- service-public.fr — SCI : quel régime fiscal ?
- BOFiP — BIC Locations meublées (BOI-BIC-CHAMP-40-20)
This topic is part of our service LMNP accountant in France | Real regime & depreciation
Need a quote or personalised advice?
Our accountancy firm supports you through all your steps. Get a free quote to review your situation and receive a bespoke fee proposal, or contact us directly.