The taxation of professional assets has sparked intense debates since the introduction of the wealth tax in 1982. These assets, central to the fortunes of the wealthiest, divide politicians and economists between fiscal justice and support for entrepreneurship. A look back at the history of this key concept.
The issue of taxing professional assets dates back to the creation of the wealth tax (IGF), predecessor to the ISF, in 1982 under President François Mitterrand, elected a year earlier. These assets, which today form the bulk of the fortunes of the wealthiest, are defined in Article 885 of the General Tax Code as “assets necessary for the principal exercise, by their owner or their spouse, of an industrial, commercial, artisanal, agricultural, or liberal profession.”
This includes tangible items like a baker's oven, a farmer's tractor, or small business premises, but above all company shares. Economist Laurent Bach, co-head of the Companies division at the Institute for Public Policies (IPP), notes that “the question of what is now called professional assets and what is considered as such arose very quickly” during the IGF's establishment.
In its initial socialist version, the text did not fully exempt these assets from the tax. However, pressures from major economic interests, particularly the L’Oréal group owned by Liliane Bettencourt, invoked the risk of massive fiscal exile. This led to a deferral of taxation in 1982, followed by total exemption in 1984.
Brought back to the forefront by economist Gabriel Zucman's proposal, this taxation still divides: the left sees it as a tool for fiscal justice and tax progressivity, while the right and business leaders defend the exemption to foster entrepreneurship and prevent capital flight.