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FR

Holding animatrice (active holding company)

A French legal concept designating a holding that not only owns its subsidiaries but actively participates in their management: setting strategy, providing shared services, exercising operational control. This qualification is required for several French tax reliefs, including the Pacte Dutreil transmission regime.

In practice

The status is earned, not declared. Tax authorities expect concrete evidence: signed management agreements, minutes of strategic decisions, invoiced management services rendered to subsidiaries. A holding that merely collects dividends is deemed passive, with significant consequences when assets are transferred. Groups that formalise their animation from year one — when the stakes are still modest — build habits that hold up under audit years later.