Radiologist in SELARL: imaging equipment depreciation in 2026

Quick answer. Diagnostic imaging equipment (CT, MRI, ultrasound) acquired by a radiologist SELARL is a depreciable fixed asset. Accelerated depreciation (CGI Article 39 A) reduces taxable income over multiple years. However, radiologist fees are VAT-exempt (Article 261 CGI), so input VAT on equipment cannot be recovered: investment costs are assessed at full tax-inclusive price. Lease financing (deductible rents) versus debt financing (asset depreciation) creates significant tax trade-offs.

A SELARL (Société d'Exercice Libéral à Responsabilité Limitée) is the standard legal structure for radiologist partnerships seeking limited liability and collective practice. It is in principle subject to corporate income tax (IS); a single-member SELARL held by one individual may instead fall under personal income tax, by default or by election. In 2026, IS applies a reduced rate of 15% on profits ≤ 42,500 EUR for smaller structures (capital >= 75% held by natural persons, fully paid in).

Critical point — VAT on medical fees: Article 261, 4-1° of the French Tax Code (CGI) exempts healthcare professionals' care services (doctors, radiologists, etc.) from VAT. This exemption has a major consequence: VAT paid on diagnostic imaging equipment cannot be recovered. Like other VAT-exempt medical professions, a radiologist practice bears a permanent VAT cost: equipment investments are assessed at full tax-inclusive price, with no input VAT credit available.

Recently, a radiologist partnership consulted us on structuring a 450,000 EUR net purchase of a CT-MRI unit. The typical mistake: budgeting at net price (450 k EUR) and expecting VAT recovery, when in reality the true tax-inclusive investment cost (540 k EUR, including 20% VAT) generates no VAT credit. The practice faces a cash shortfall and exposure to VAT deduction risk upon audit.

Definition and accounting classification#

Diagnostic imaging equipment is a tangible fixed asset: CT scanner, MRI, ultrasound, digital capture sensors, entire imaging suite electronics. It appears on the balance sheet as fixed assets (account 213 in the French Chart of Accounts). Unlike supplies and consumables (films, contrast agents), medical equipment has a multi-year useful life and significant acquisition cost.

Typical useful-life spans (guidance ranges):

• Multi-detector CT scanner: generally 5 to 7 years (technology ages, maintenance grows costly);
• MRI unit: 7 to 10 years (longer physical lifespan, but software obsolescence is real);
• Ultrasound system: 4 to 6 years (more compact, frequent software updates);
• Imaging room infrastructure: 8 to 12 years.

These spans are not prescriptive. A practice may justify a different useful life if documented and consistent with actual operating life and maintenance plans. Tax authorities accept reasonable variation, but will challenge choices in an audit without supporting documentation (maintenance contracts, replacement forecasts, etc.).

Straight-line vs. accelerated depreciation#

Straight-line depreciation (default method): spreads cost evenly across the useful life.

Example: 100,000 EUR net CT scanner over 6 years = 16,667 EUR annual depreciation expense.

Accelerated depreciation (CGI Article 39 A): available for new assets with useful lives >= 3 years, including medical imaging equipment (qualified under Schedule II Article 22 of the CGI). It front-loads tax deductions in the early years.

Multiplier applied (straight-line rate × coefficient by useful life):

Practical example: brand-new CT scanner at 100,000 EUR net, 6-year useful life, accelerated depreciation:

The final year switches to 100% once the accelerated rate falls below the remaining straight-line rate. Tax benefit: 29,170 EUR deduction year one (vs. 16,667 EUR under straight-line), immediately reducing IS liability.

The financing method creates a decisive tax trade-off: rent (equipment lease) or buy (debt-financed purchase).

Equipment lease#

Definition: the lessee rents equipment from a leasing company for the contract term, with an option to purchase at the end for a residual value (typically 1% of original price).

Accounting and tax treatment:

• Lease payments are fully deductible as operating expenses under Article 39 CGI;
• No depreciation is recorded by the lessee (asset does not appear on lessee's balance sheet);
• Upon purchase option exercise, the asset enters the balance sheet at residual value and depreciates over remaining useful life.

Advantages:

1. Immediate rent deductibility (accelerates tax write-off) ;
2. Technology flexibility: lease end = opportunity to upgrade easily ;
3. Off-balance-sheet initially: rented equipment does not burden balance-sheet ratios (useful for bank covenant compliance).

Disadvantages:

1. Total cost typically exceeds purchase-via-debt (lessor's margin) ;
2. Loss of accelerated depreciation opportunity (strongest early-year tax lever).

Purchase via debt financing#

Definition: the practice buys new or used equipment using bank debt or specialized medical equipment financing.

Accounting and tax treatment:

• Equipment enters balance sheet (account 213) at tax-inclusive acquisition cost (since input VAT is not recoverable) ;
• Depreciation expenses (e.g., accelerated, more powerful years 1–3) ;
• Loan interest is fully deductible under Article 39 CGI ;
• Loan principal is not deductible (it is debt repayment, not an operating expense).

Advantages:

1. Accelerated depreciation available = powerful early-year tax lever ;
2. Asset ownership = future flexibility (resale, transfer, pledge) ;
3. Total cost typically lower than lease over full useful life.

Disadvantages:

1. Immediate cash outlay: acquisition fees (insurance, notary, registration) ;
2. Technology risk: obligation to depreciate asset even if technologically obsolete.

Tax trade-off: worked example#

Scenario: CT scanner acquisition at 100,000 EUR net (= 120,000 EUR tax-inclusive, 20% VAT unrecoverable).

Option 1 — Equipment lease: annual rent 24,000 EUR over 5 years (total = 120,000 EUR, matching total tax-inclusive cost).

Option 2 — Purchase + accelerated depreciation (6-year useful life):

Analysis: over five years the lease delivers a comparable, even slightly higher cumulative saving (18,000 EUR vs. 15,119 EUR), but accelerated depreciation front-loads the benefit into years 1–3 — freeing up cash earlier, often decisive when launching new equipment. The lease spreads the benefit evenly. If the practice forecasts losses in later years, lease payments may be more valuable (losses may offset other income).

Definition and tax structure#

A Groupement d'Intérêt Économique (GIE) (French Commercial Code Articles L251-1 et seq.) is a lightweight partnership structure for shared assets. Multiple radiologists (each in individual SELARL or SELAS) form a GIE to collectively acquire, maintain, and depreciate high-cost imaging equipment.

Accounting structure:

• Each radiologist is a partner in the GIE ;
• GIE receives capital contributions (cash or assets) from each partner ;
• GIE records equipment on its balance sheet and depreciates it ;
• Monthly, GIE invoices partners for pro-rata usage fees (based on utilization hours or headcount).

Tax transparency: GIE is tax-transparent. It does not file a corporate tax return. Each partner includes his pro-rata share of GIE profit or loss in his personal return (or his SELARL's return).

Accounting example — GIE « Imaging Partnership »#

Three radiologists (A, B, C) form a GIE to pool a CT-MRI unit costing 120,000 EUR tax-inclusive.

Initial capital contributions:

• Radiologist A contributes 40,000 EUR cash;
• Radiologist B contributes 40,000 EUR cash;
• Radiologist C contributes 40,000 EUR cash.

GIE opening balance sheet (Year 1):

Year 1 depreciation (accelerated, 6-year life):

Expense = 120,000 EUR × 29.17% = 35,040 EUR (rounded to 35,000 EUR).

GIE Year 1 P&L:

• Revenue (usage fees billed to partners): 45,000 EUR (e.g., 15,000 EUR per radiologist)
• Expense (depreciation): 35,000 EUR
• Net income: 10,000 EUR profit (or break-even if fees cover maintenance).

Each radiologist A, B, C includes 1/3 of GIE net income (approx. 3,333 EUR) in his personal taxable income.

GIE advantages:

1. Spreads heavy investment cost across multiple practitioners ;
2. Economies of scale (one maintenance contract for three radiologists) ;
3. Flexibility: partner exits or joins without restructuring main practice.

Medical fee exemption and VAT pass-through#

Article 261 of the CGI exempts healthcare professional fees from VAT. This is patient-friendly (no VAT on consultation), but costly for the practice: VAT on operating expenses is not deductible.

Direct consequence: when a radiologist buys a CT scanner at 100,000 EUR net (VAT 20% = 20,000 EUR), he cannot recover the 20,000 EUR VAT. The true cost of investment is 120,000 EUR tax-inclusive.

This permanent VAT cost affects financing decisions. A practice budgeting 100,000 EUR (net, thinking VAT will be recovered) faces a 20,000 EUR cash shortfall. Banks typically lend on net amounts, leaving this gap uncovered.

VAT threshold registration: not applicable#

Some radiologists ask: "Can we claim VAT small-business relief if gross fees stay below a threshold?"

Answer: no. Small-business VAT relief applies to commercial or service activities. For exempt professions (under Article 261), the exemption status is permanent: no VAT to collect, hence no VAT to recover. It is an unfavorable regime but applies universally to healthcare professionals in France.

SELARL with managing partner (non-salaried) vs. SELAS with salaried president#

SELARL with managing partner (non-salaried status):

• Social regime: registration with CARMF (physicians' pension fund) — not CARPIMKO, which covers paramedical auxiliaries; TNS contributions based on management remuneration ;
• Tax: corporate tax (IS) by default (personal income tax remains possible only for a single-member SELARL held by one individual) ;
• Depreciation: fully available, no restrictions.

SELAS with salaried president (assimilated employee status):

• Social regime: assimilated-employee payroll (employee + employer contributions, combined ~42–45% of salary) ;
• Tax: IS mandatory ;
• Dividends: subject to PFU 31.4% (personal income tax 12.8% + social charges 18.6%, per 2026 LFSS) ;
• Depreciation: fully available, no restrictions.

Both structures allow full equipment depreciation in 2026. Choice depends on governance (solo vs. group), not on tax treatment of depreciation.

Imaging partnerships vs. solo radiologists#

A solo practice finances equipment alone and claims full depreciation. A multi-partner practice may pool equipment (via GIE) or distribute ownership proportionately (each radiologist holds equal equity in a multi-member SELARL that owns all equipment).

Multi-member SELARL is standard: each radiologist is an equal shareholder in the partnership, which owns collective assets and files a consolidated tax return.

Over a decade advising radiology practices, we consistently observe two underestimated risks: permanent VAT costs and technology obsolescence.

On VAT pass-through: most radiologists think "I will buy a 100k EUR CT scanner," forgetting this is net price. The unrecoverable 20k EUR VAT creates a 20% financing gap. Banks lend on net figures, leaving a cash shortfall. We insist: budget at full tax-inclusive price (120k EUR in this example).

On technology lifespan: a CT scanner purchased in 2026 with a 6-year accounting useful life may be clinically obsolete in 4 years. The practice must continue depreciating the asset even if unused, or recognize a loss. Accelerated depreciation is valuable but assumes equipment replacement every 4–5 years, not 6.

On shared ventures: GIEs are powerful when partners are stable and aligned. If radiologists disagree or withdraw, the GIE creates accounting and tax complications. A standard multi-member SELARL is often simpler and more durable.

At Hayot Expertise, we advised a four-radiologist group near Paris on pooling an MRI unit via GIE. Accelerated depreciation generated IS savings of 28k EUR over three years combined—a significant benefit that funded much of the software integration and staff training costs.

Hayot Expertise advice. Before committing to high-cost imaging equipment, ask three questions: (1) Should we lease or buy? Work with your accountant and a leasing company to simulate the tax trade-off. (2) What is the realistic useful life for this equipment in your practice? Ignore accounting standards; account for technology refresh cycles and clinical strategy. (3) Will you pool equipment with other radiologists or keep it solo? If pooling, formalize it immediately with clear GIE bylaws. If solo, a straightforward multi-member SELARL is better. Finally, remember: VAT is not recoverable. Finance at full tax-inclusive price, not net price.