Shareholders' Current Account France 2026: Deductible Interest Rate & Best Practices

Updated April 2026 — The shareholders' current account (compte courant d'associé — CCA) is one of the most common financing tools used by French SME directors. Its flexibility is genuine, but poor management leads to significant tax reassessments. This guide covers the deductibility conditions, the 2026 maximum rate, requalification risks and documentation requirements.

A shareholders' current account is a cash advance made by a shareholder (or member) to the company. It appears on the liability side of the balance sheet (account 455 — Associés, comptes courants) as a debt owed by the company to its shareholder.

It can be:

• In credit (the shareholder has lent money to the company) — the typical case;
• In debit (the company has advanced money to the shareholder) — a legally restricted and fiscally risky situation.

Important: A debit CCA is prohibited in a SARL (art. L223-21 Code de commerce) for the manager (gérant) and members. In a SAS, the prohibition applies only to executive directors, not to non-executive shareholders.

Yes, subject to two cumulative conditions under CGI art. 39-1-3°:

Condition 1 — Share capital must be fully paid up#

Deductibility is only available if the company's share capital is fully called and paid. If any portion remains unpaid, no CCA interest is deductible.

Condition 2 — Interest rate must not exceed the statutory cap#

The maximum deductible rate is published quarterly by the French tax authority (DGFiP) on impots.gouv.fr. It equals the annual average of variable-rate effective lending rates applied by credit institutions to businesses on loans with an initial term exceeding two years.

Indicative 2026 rates (always verify on impots.gouv.fr):

⚠️ The rate changes quarterly. Always verify before each payment or year-end close. Any interest paid above the cap is added back to taxable income.

There is no statutory requirement to formalise the CCA in a written agreement. However, it is strongly recommended for three reasons:

1. Proof of the debt's nature — without documentation, the tax authority may recharacterise payments as deemed dividends or an abnormal management act.
2. Securing the interest rate — the agreement specifies the rate applied and its reference to the statutory cap.
3. Protection in insolvency — a formalised agreement strengthens the shareholder's position as a creditor in collective proceedings.

The agreement should state: the maximum CCA balance, the interest rate (or reference to the legal cap), repayment conditions, and duration.

A shareholder may opt for a blocked CCA (CCA bloqué), waiving repayment demands for a fixed period (typically 2–5 years). Benefits include:

• Reassuring banks (treated as quasi-equity in credit analysis);
• Interest remains deductible under the same conditions;
• Supports financing applications with a "financial backing certificate".

Abnormal management act (acte anormal de gestion)#

If the rate exceeds the cap, excess interest is disallowed. If CCA terms are abnormally favourable to the shareholder at the company's expense, the excess may be treated as an abnormal management act and added back to taxable income.

Deemed dividend recharacterisation#

Interest paid outside the deductibility conditions can be recharacterised as deemed dividends (CGI art. 109-1-2°), taxable in the hands of the shareholder as investment income — typically at the 30% flat tax (PFU).

Thin capitalisation rules#

For corporate groups, thin capitalisation rules (CGI art. 212) cap intra-group interest deductions when debt-to-equity ratios exceed thresholds. These rules generally do not apply to CCA between individuals and their companies.

Interest received by an individual shareholder is taxed as investment income (revenus de capitaux mobiliers):

• Flat tax (PFU): 12.8% income tax + 17.2% social levies = 30% total.
• Option to apply the progressive income tax scale if more favourable.

For a corporate shareholder, interest received is standard corporate income subject to IS.

1. Check the cap every quarter — never apply a fixed rate across multiple periods without verification.
2. Draft a written agreement as soon as the CCA is opened.
3. Fully pay up the share capital before accruing interest.
4. Monitor the CCA balance — a very high CCA relative to equity can signal under-capitalisation.
5. Coordinate CCA interest and dividends — depending on the shareholder's marginal tax rate, an interest/dividend mix may be optimal.

• CCA: tax and optimisation
• Dividends vs salary for directors
• SARL tax regime 2026
• Tax advisory Paris