Shareholder current accounts in France: tax rules, 2026 rates and practical decisions for directors

Updated 25 May 2026 — Written by Samuel HAYOT, chartered accountant (expert-comptable) Paris, reviewed by the Hayot Expertise tax team.

The compte courant d'associé (CCA) — a shareholder current account — is one of the most widely used financing instruments in French SMEs and startups, precisely because it bypasses the formalities of a share capital increase or a bank loan. But that apparent simplicity conceals a precise tax regime, strict rate ceilings and several traps that, if mishandled, expose the company to reassessment during a tax audit.

This article sets out how the CCA works, the maximum deductible rate applicable in 2026, the tax treatment for the lending shareholder, and the concrete decisions a director needs to make.

In short: A properly structured creditor CCA — with fully paid-up share capital, a rate compliant with Article 39-1-3° of the French Tax Code (Code général des impôts, CGI), and a written agreement — generates tax-deductible interest for the company and investment income taxed at the PFU flat rate of 30% for the shareholder, with no social charges. Badly calibrated, it becomes a hidden distribution.

A CCA is a receivable held by a shareholder (or shareholder-director) against their own company. The shareholder advances funds; the company records them as a liability on its balance sheet. This is not share capital: the funds are repayable — in principle on demand. That is both its strength and its risk.

Who can hold a CCA? Any shareholder or partner, whether an individual or a legal entity, depending on the corporate form. In SARLs (private limited companies, art. L. 223-21 of the Code de commerce), a debit CCA (loan from the company to the shareholder) is prohibited for individual shareholders, though legal entities are permitted. In SAS and SA structures, a director's debit CCA is a regulated agreement requiring AGM approval.

This is the first point to watch. A company may only deduct interest paid on shareholder current accounts up to a ceiling rate set each quarter by the Direction générale des finances publiques (DGFiP). That rate corresponds to the average effective rate charged by credit institutions on variable-rate loans to businesses with an initial term exceeding two years — commonly referred to as the TMOE (taux moyen des obligations d'entreprises), published by the Banque de France.

Table — Maximum deductible CCA rate (art. 39-1-3° CGI)

The figures above are indicative. The applicable rate is the one published for the last quarter of the company's financial year. Always check the current figure on bofip.impots.gouv.fr or with your adviser before each year-end closing.

Mandatory prior condition: The company's share capital must be fully paid up before any interest on a CCA can be deducted. Partially unpaid capital cancels the deduction entirely, even if the rate is otherwise compliant.

Interest received by a shareholder on their CCA constitutes revenus de capitaux mobiliers (investment income), subject to:

• By default: the prélèvement forfaitaire unique (PFU) flat tax of 30% — 12.8% income tax plus 17.2% social levies.
• On a global annual opt-in: the progressive income tax scale (barème progressif de l'IR), with partial CSG deductibility of 6.8% if the income is taxed under the scale.

This interest generates no social charges (cotisations sociales) — no URSSAF, no RSI, no pension fund contributions. That is its primary tax advantage over additional salary. But this advantage must be weighed against other criteria (see the comparison table below).

Our reading: For a shareholder-director whose marginal income tax rate (tranche marginale d'imposition, TMI) is 30% or 41%, remuneration via CCA interest is less costly in social charges than salary, but creates no pension entitlement. The optimal balance depends on the director's age, their existing retirement coverage, and the company's applicable IS rate.

Take a SARL subject to IS at the reduced rate of 15% (up to €42,500 of profit) and the standard rate of 25% beyond that, with a fully paid-up share capital.

• Gross interest paid: €100,000 × 5% = €5,000
• Applicable rate ceiling (FY 2025 assumption): 5.07%
• Deductible interest: €5,000 (rate is below the ceiling — compliant)
• IS saving for the company (25% rate): €5,000 × 25% = €1,250
• Shareholder tax (PFU 30%): €5,000 × 30% = €1,500
• Net received by the shareholder: €3,500
• Net cost to the company (charge after IS): €5,000 − €1,250 = €3,750

Had the rate been set at 6% (above the ceiling), the excess portion (0.93% × €100,000 = €930) would have been reintegrated into the company's taxable income — no IS deduction possible — while remaining fully taxable for the shareholder. A double penalty.

A creditor CCA left interest-free is not in itself illegal, but it draws the attention of the tax authority for two reasons:

1. Suspicion of an abnormal management act (acte anormal de gestion): The company benefits from an interest-free loan from its shareholder when it should have paid market-rate interest. In an audit, the DGFiP may argue that this waiver of interest constitutes a taxable benefit for the company (deemed income reintegrated into taxable profit) or an abnormal management act on the part of the shareholder.
2. Callable on demand: A CCA without a written agreement specifying a repayment notice period is repayable at any time. In a cash-flow crisis or shareholder dispute, this can destabilise the company overnight.

What the administration focuses on first: The consistency between the rate applied and the market rate, the full payment of share capital, the existence of a written agreement, and equal treatment across all shareholders.

Abandonment of the current account (abandon de compte courant)#

The shareholder waives their claim against the company. The tax consequences are:

• For the company: The waiver constitutes exceptional income — unless a recovery clause (clause de retour à meilleure fortune) is included in the deed (in which case the waiver is only taxable when the company's financial position recovers). This option must be anticipated when drafting the agreement.
• For the shareholder: The loss is generally non-deductible for an individual shareholder (except in specific circumstances justifying a direct professional connection).

Conversion into share capital (incorporation au capital)#

The shareholder converts their receivable into shares or parts sociales. This makes it possible to:

• Strengthen the company's equity base (useful for bank ratios and public procurement requirements)
• Avoid a cash repayment
• Potentially benefit from a more favourable capital gains tax regime on exit

Conversion requires a formal procedure: deed of transfer, extraordinary general meeting, articles amendment, INPI registration. We cover this in detail in our dedicated article: Capital increase by incorporation of shareholder current account.

For companies whose shareholders are legal entities (notably in holding/subsidiary structures), Article 212 of the CGI introduces a thin capitalisation rule: interest paid to related companies may be restricted if the borrowing company is considered undercapitalised — where the debt-to-equity ratio exceeds 1.5 or interest exceeds 10% of EBITDA, among other conditions.

This rule does not apply when the lending shareholder is an individual, but it is central to intra-group structures. It must be assessed systematically before sizing any intra-group CCA.

1. Share capital 100% paid up — check the extrait Kbis and confirm any in-kind contributions have been released.
2. Rate applied ≤ DGFiP ceiling for the closing quarter — consult bofip.impots.gouv.fr.
3. Written CCA agreement signed — covering the rate, term, repayment conditions, and a recovery clause if abandonment is being considered.
4. Correctly recorded in account 455 (associés — comptes courants) — with supporting documentation for all movements.
5. Interest declared in the tax return (liasse fiscale) — on form 2058-A and the schedule of interest paid.

In a services SME file (turnover ~€2 million), the managing shareholder had fed the CCA over four consecutive financial years for a total of €280,000, with no written agreement and no interest. During a tax audit, the DGFiP reclassified the unpaid interest as an abnormal management act, calculated deemed income on the basis of the market rate, and reintegrated that amount into the company's taxable profit. The result: IS reassessment across three financial years, a 10% surcharge, and a constrained regularisation period.

The lesson: even an interest-free creditor CCA can generate a tax reassessment if the administration demonstrates that the waiver of interest serves no economic logic.

A CCA is rarely analysed in isolation. It sits within a broader strategy:

• Remuneration arbitrage: Read our analysis on dividends vs salary vs interest to position the CCA within your overall director compensation strategy.
• Conversion into equity: When does it make sense to consolidate a CCA into share capital rather than leaving it as debt? See Capital increase by CCA incorporation.
• Retirement planning: The CCA creates no pension rights. For directors approaching retirement age, the trade-off between a CCA and tax-deductible pension contributions (plan d'épargne retraite, PER) is structurally significant. See PER for directors 2026.

• The TMOE rate has risen since 2022: it is now higher than it was during the 2020–2021 financial years, which widens the margin for remunerating CCAs at a deductible level. This window could narrow if rates fall.
• The DGFiP is intensifying its scrutiny of CCAs in dissolution and liquidation files, where large unremunerated balances raise questions about the reality of the receivable.
• The mandatory e-invoicing rollout (facturation électronique obligatoire, progressive deployment 2026–2027) will mechanically improve traceability of intra-group flows, making undocumented CCAs more visible to the administration.

• Share capital fully paid up
• Interest rate ≤ DGFiP ceiling (art. 39-1-3° CGI) for the closing quarter
• Written CCA agreement drafted and signed (rate, term, repayment conditions)
• Account 455 correctly recorded with supporting documents
• Interest declared as investment income (revenus de capitaux mobiliers) in the tax return
• PFU vs progressive income tax scale option reviewed with your adviser before filing
• Recovery clause (clause de retour à meilleure fortune) included if abandonment is being considered
• Article 212 CGI analysis carried out if the lender is a related legal entity

This article is for information purposes only. It does not replace a personalised analysis of your specific situation, your accounting records, and the law in force at the date of your financial year-end. The rates mentioned are indicative and must be verified against official sources before application.