Shareholder current account France: interest cap and key rules 2026

A shareholder current account (compte courant d'associé, or CCA) is one of the most widely used financing tools in French SMEs and holding structures — and one of the most poorly managed. Its appeal is straightforward: no shareholder meeting, no change to the articles of association, no bank committee. But this flexibility comes with precise tax conditions, firm legal prohibitions depending on the company type, and a significant risk of shareholder dispute if the rules are not set out clearly from day one.

This guide covers the practical mechanics of the CCA, the interest deductibility conditions in 2026, the prohibition on debit balances, and the role of the blocking agreement (convention de blocage). It is aimed at directors and shareholders of SASU, SARL, SAS and SCI structures operating in France.

In short: a shareholder current account is a repayable advance from a shareholder to the company. Interest paid by the company is deductible up to the reference rate published by the French tax authority (DGFiP) — set at 4.55% for financial years ending 31 December 2025 — provided the share capital is fully paid up. A debit balance is strictly prohibited for individual directors in SARL and SAS structures. A written agreement remains the most effective safeguard.

A CCA is a debt owed by the company to one of its shareholders. The shareholder advances funds to the company — or leaves amounts due to them at the company's disposal — and the company owes that amount back under conditions agreed in advance. It is not a capital contribution: the funds remain in the company's liabilities and can, in principle, be repaid.

In practice, a CCA is created in several situations:

• the shareholder transfers funds to the company's bank account to cover a specific need;
• the shareholder temporarily waives reimbursement of expenses advanced or deferred salary;
• a holding company advances funds to a subsidiary as part of intragroup cash management.

This is what distinguishes a CCA from a bank loan (no collateral, no credit committee) and from a capital increase (no change to the distribution of shareholder rights, simpler procedure).

This is the most frequently asked question — and the one that generates the most errors in client files.

Article 39-1-3° of the French Tax Code (CGI) caps the deductibility of interest paid to shareholders. The company can deduct interest provided the rate applied does not exceed the average rate on variable-rate loans with a maturity of more than two years granted to businesses, published quarterly by the Banque de France and used by the DGFiP in its tax guidelines (BOFiP).

For financial years ending 31 December 2025, this rate stood at 4.55%. This rate changes every quarter and depends on the year-end closing date — not on the date the CCA was set up. You must check the rate in force at the time of the year-end close, not rely on a fixed figure.

The portion of interest exceeding the cap remains contractually due to the shareholder, but is not tax-deductible for the company. The excess must be added back in the tax return (liasse fiscale) as a non-deductible expense.

Second condition: interest deductibility requires the share capital to be fully paid up. A SARL whose share capital has only been 50% paid up cannot deduct interest on shareholder current accounts, even where the rate is within the cap. Tax authorities routinely check this point during an audit.

This is the most serious restriction — and the least well known among directors.

A CCA is said to have a debit balance when it is the company that advances funds to the shareholder (rather than the other way around). In other words, the CCA appears as an asset on the company's balance sheet — the company is owed money by its shareholder.

For SARL companies, Article L.223-21 of the French Commercial Code prohibits individual managers (gérants), whether or not they are shareholders, from borrowing from the company, obtaining overdrafts, or benefiting from guarantees granted by the company. This prohibition extends to their spouses, direct relatives and any person acting as an intermediary.

For SAS and SASU companies, the equivalent prohibition (Article L.225-43, applied by cross-reference) covers individual presidents and directors.

The consequence is absolute nullity of the transaction. The director must repay the amounts immediately, and the operation can expose them to personal liability — and in serious cases, to criminal charges for misuse of corporate assets (abus de biens sociaux).

What we see in practice: a debit balance on a CCA often arises inadvertently. The director reimburses advances, draws down on unsubstantiated expense notes, or regularly withdraws sums without waiting for the year-end result to be confirmed. The current account tips into debit without anyone noticing until the annual close. This is one of the most common triggers for a tax audit adjustment on this line.

A blocking agreement (convention de blocage) is not legally mandatory, but it is strongly recommended as soon as the amounts are material or several shareholders are involved.

It takes the form of a written undertaking in which the shareholder commits not to withdraw funds during a specified period. In return, this commitment can:

• strengthen the company's net equity in the eyes of financial partners, with some banks treating the blocked CCA as quasi-equity;
• secure continuity of operations when cash flow is under pressure;
• send a positive signal when applying for bank financing or when a new investor is entering.

The agreement should specify: the identity of the parties, the amount covered, the blocking period, the conditions for early release (with or without notice), the interest rate if applicable, and the date from which interest is calculated.

No notarised deed is required — a signed document between the parties is sufficient — but it must be kept with the company's legal records and disclosed in the notes to the accounts when the amounts are material.

A SAS with fully paid-up share capital of €50,000. The majority shareholder placed a CCA of €120,000 at the company's disposal on 1 March 2025. The agreement provides for a rate of 5% per annum.

Financial year ending 31 December 2025 (10 months of availability).

• Contractual interest: €120,000 × 5% × 10/12 = €5,000
• DGFiP cap at 31/12/2025: 4.55%
• Deductible interest: €120,000 × 4.55% × 10/12 = €4,550
• Non-deductible amount to be added back: €450

This difference (€450) must be added back in the tax return. The shareholder receives the full €5,000 in interest, but the company can only deduct €4,550.

This interest income is taxable in the hands of the shareholder as investment income (revenus de capitaux mobiliers), subject to the flat tax (PFU) at 31.4% (12.8% income tax + 18.6% social contributions following the CSG increase effective 1 January 2026).

The CCA is the tool of choice for short-term flexibility. As soon as it finances a structural need, converting it into capital or sourcing appropriate bank financing is the more appropriate path. For the conversion procedure, see our article on incorporating a current account into share capital.

The shareholder current account takes on additional complexity in group structures. A holding company advancing funds to a subsidiary via a CCA must document the intragroup agreement with the same rigour as a third-party loan — internal transfer pricing remains on the tax authority's radar.

In a holding structure, the CCA is also used to channel cash upward: a subsidiary deposits its surplus with the holding company (a simplified form of cash pooling). This arrangement is entirely legitimate but must comply with the formality and rate conditions described above. The holding company, as a legal entity, is not subject to the debit balance prohibition that applies to individual directors — but it remains subject to transfer pricing rules and the abuse-of-law doctrine if the terms are not at arm's length.

A management consulting SARL with three shareholders. The managing director (gérant) had been making regular withdrawals from his current account since the company was founded, believing he was simply reimbursing expenses advanced on behalf of the business. At the first year-end close, the accountant discovered that the CCA had a debit balance of €28,000.

The problem: the gérant is an individual, and the SARL falls under Article L.223-21 of the French Commercial Code. The transactions are void. The gérant was required to repay the full amount immediately — failing which he faced personal liability and, in the most serious reading, potential criminal exposure for misuse of corporate assets.

The cabinet assisted with the regularisation: repayment of the debit balance, implementation of a separate expense account subject to supporting documents, and signature of a proper CCA agreement for future advances (in the correct direction: from the shareholder to the company). The situation was resolved before any audit, but the repayment timeline placed real pressure on the director's personal cash flow.

This kind of situation is entirely avoidable with a monthly balance check and a systematic end-of-quarter reminder.

The DGFiP routinely reviews shareholder current account treatment during accounting audits (VASFE or vérification de comptabilité). The main points under scrutiny:

• Share capital fully paid up: if not, no interest is deductible — full stop.
• Rate applied vs DGFiP cap: the excess is added back and can attract penalties if the overrun is deliberate.
• Written agreement: no agreement or unspecified rate signals either an interest-free account (accepted by the administration) or potential recharacterisation as an abnormal management act if the rate is excessive.
• Debit balance: an immediate red flag. The administration may also recharacterise amounts received as disguised salary or hidden distributions.
• Reporting of interest income: interest paid on a CCA must appear on the company's annual investment income declaration (form 2561, also called IFU) and be declared by the shareholder.

A well-managed CCA is checked at every accounts close. The minimum control checklist:

• Balance per shareholder at the closing date
• Direction of the balance: credit (shareholder lent to company — compliant); debit for an individual in a SARL/SAS — immediate alert
• Interest accrued for the period, applying the DGFiP rate at the closing date
• Tax add-back for any excess interest in the tax return
• Confirmation that share capital is fully paid up
• Update or signature of the agreement if terms have changed

This systematic approach prevents tax adjustments and shareholder disputes. For a broader view of financial management in your company, our guide on key financial KPIs for SMEs provides a complementary perspective.

We review the agreement, the applicable rate, the legal structure and the tax implications as part of our accounting and tax advisory service.

Updated 2026-06-14. This article provides general information and does not replace personalised professional advice. For your specific situation, consult a registered expert-comptable.