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Wealth and inheritance, Marine Tondelier

Wealth tax (IFI, ISF): 2% Zucman tax above €100m, climate wealth tax (ISF) restored

Direction of change: increase, compared with current law.

The lever. Taxation of wealth: real estate wealth tax (IFI), return of a tax on all assets, or a tax on very large fortunes. Direction rule: ↑ heavier taxation of wealth.

« Mettre en place une taxe Zucman de 2 % au-delà de 100 millions d’euros de patrimoine. Étendre les conditions de l’exit tax afin de maintenir une contribution fiscale des émigrés fiscaux établissant leur domicile fiscal hors de France. Rétablir l’Impôt sur la Fortune (ISF) en lui ajoutant une composante climatique pour orienter le patrimoine vers des actifs verts. »1

Translation by the editorsIntroduce a Zucman tax of 2% above €100m of wealth. Extend the conditions of the exit tax in order to maintain a tax contribution from tax emigrants establishing their tax domicile outside France. Restore the wealth tax (Impôt sur la Fortune, ISF), adding a climate component to it to steer wealth towards green assets.

Encoding

Position linked to options of the cost schedule, with no parameter to set: see the costing.

Costing

Announced by the candidate

not announced

The programme does not cost this measure.

Published costings

none

No external costing of this position recorded to date.

Our calculation

+€24bn

per year for the public accounts, new revenue, range +€18bn to +€30bn.

The calculation

  • Minimum tax of 2% on fortunes above €100m (« taxe Zucman », private member's bill passed by the National Assembly in February 2025), static: high estimate, that of its proponents (Gabriel Zucman, National Assembly report no. 930 and Senate report no. 689); the administration has not simulated it; estimates that take account of exile, tax optimisation or the deduction of corporate income tax are much lower (€2bn to €5bn): Option costed by the source: a gain of €20bn (15 to 25) per year.
  • Reinstate the wealth tax (ISF) (2017 base): revenue loss from its abolition, mechanical effect (Conseil d'analyse économique): Option costed by the source: a gain of €3.75bn (3 to 4.5) per year.

Assumption by the editors. Partial costing. Reading adopted: « rétablir l'ISF » [“restore the ISF”] means the return of the 2017 ISF, whose entry threshold (€1.3m) is taken up by the Budget 2027 dossier (26 August 2026); the cost schedule gives its net gain relative to the IFI. The climate component, which modulates the tax schedule according to the carbon footprint of investments, is not costed (no rates): depending on how it is set, it may raise or lower this amount. The Zucman tax (2% minimum tax on fortunes of more than €100m) is costed at the upper end of the estimates, €15bn to €25bn (about 20), that of its proponents (Gabriel Zucman, National Assembly report no. 930 and Senate report no. 689); the administration has not simulated it; estimates that take account of exile, tax optimisation or the deduction of corporate income tax are much lower (€2bn to €5bn). Not costed: the extension of the exit tax (parameters not given).

Current law, sources and limits of the cost schedule

Current law. IFI (real estate wealth tax, since 2018): net real estate assets above €1.3m; scale from 0.5% to 1.5% above €0.8m; capped at 75% of income. 194,000 tax assessments in 2025, for €2.3bn in budget accounting (€2.7bn in national accounts); €3.1bn forecast for 2026. The ISF raised €5.1bn in 2017 (358,000 households). The PLF 2026 creates a tax on the financial assets of holding companies (+€1.0bn forecast). No minimum tax on very large fortunes (« taxe Zucman »): the private member's bill adopted by the National Assembly in February 2025 was rejected by the Senate in June 2025.

Horizon. Full year; ISF counterfactual in 2022 euros, not updated for 2032; minimum tax estimated on 2024 fortunes (Challenges ranking), not updated.

Limits. Restoring the wealth tax (ISF): central value, €3.75bn, midpoint of the range of the Conseil d'analyse économique (Council of Economic Analysis, 2025), which puts the revenue loss from abolishing the ISF at between €3bn and €4.5bn, mechanical effect only (lower and upper bounds). Benchmarks: €3.2bn, ex ante revenue loss from converting the ISF into the IFI according to the impact assessment of the PLF 2018 (Senate general report); €4.5bn net from the IFI according to a press summary of the France Stratégie evaluation committee (2022 counterfactual). The 2026 yield of the tax on holding companies depends on the text adopted; the ISF and this tax partly bear on the same assets (declared overlap). Minimum tax of 2% on wealth above €100m (« taxe Zucman »): costed and added at the upper end of the estimates, €15bn to €25bn (about 20, « avec une marge d'erreur d'environ 5 milliards » [“with a margin of error of about 5 billion”] according to Public Sénat), a static estimate by its promoters alone (the economists heard, including Gabriel Zucman), taken up in the reports of the National Assembly (no. 930) and the Senate (no. 689); it is the only static estimate read of the scheme adopted by the National Assembly in February 2025. The administration has not simulated it: the DGFiP stated that it could not do so, for lack of a valuation of financial and business assets. The estimate starts from the Challenges ranking (€1,228bn for the 500 largest fortunes in 2024) and a current tax rate of about 0.3% of wealth. Estimates that take into account exile, optimisation or the deduction of corporate income tax are much lower, €2bn to €5bn: if corporate income tax were deducted, the yield would fall to €2bn or €3bn according to Antoine Levy (cited by the Senate); the figures of about €5bn in circulation take into account exile and optimisation, or this deduction; according to the Senate report, the departure of the three largest fortunes would halve the yield; the Institut de l'entreprise (2026) speaks of a yield « divisé par quatre » [“divided by four”]. CAE Focus no. 118 does not cost this tax (it simulates tax exile for tax increases of €2bn and €4bn). The amount counted is therefore the top of the range, to be read as such. As a differential tax « tous impôts confondus » [“all taxes combined”], it would yield slightly less if the ISF were restored, since the ISF paid on the same assets would be deducted; no source read measures this common share, and the two amounts are added together. A floor limited to billionaires is not costed.

How to read these amounts. These are static costs and revenues, with no feedback effect, over a full year: nothing on growth, employment or the revenue that economic activity would gain or lose. A higher net cost does not on its own make a worse policy, nor net savings a better one: each programme rests on an economic model (demand-led stimulus, lower compulsory levies, consolidation of the public accounts…) that the cost schedule does not settle. GDP itself measures a volume of activity, not well-being or the usefulness of what is produced. Economic models and feedback effects.

This lever in the method · Costing for Marine Tondelier

  1. Pour une prospérité écologique – Le nouveau programme des Écologistes (Projet 2027), version 1 of 25 August 2026, p. 66. Open the document at this page.

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