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FranceEntreprendre Service Public

Shareholder-loan interest deduction caps rise to 4.45% for late-2026 closings

New deductible-interest caps of 4.40 %, 4.43 % and 4.45 % for years closing 30 September–30 December 2026; interest above the cap stays non-deductible.

By Taxxa AI OyPublished 16 October 2026

Tax

Industry: Across industries

Companies that pay interest on shareholder current accounts (comptes courants d'associés) can deduct that interest from taxable profit only up to a reference rate — the taux maximal d'intérêts déductiblesService Public — which depends on when the company's financial year closesService Public. The rate is set in the articles or the current-account agreement, and any interest above the reference rate for the closing period is not deductibleService Public. The updated table now covers closings through the end of 2026Service Public.

Three new closing periods carry new caps: financial years closing between 30 September and 30 October 2026 are capped at 4.40 %Service Public, between 31 October and 29 November 2026 at 4.43 %Service Public, and between 30 November and 30 December 2026 at 4.45 %Service Public. The table previously stopped at 4.33 %Service Public (the rate for closings from 30 June through 29 September 2026)Impots, so the new caps are higher. Five expired 2025 periods (closings from 31 May to 30 October 2025, at 5.32 % down to 4.81 %) drop out of the table.

For an « exercice de 12 mois », the table gives one maximum rate per « clôture de l’exercice » band: 4.40 % for closings between 30 September and 30 October 2026, 4.43 % between 31 October and 29 November 2026, and 4.45 % between 30 November and 30 December 2026. Interest paid to shareholders above the rate for the company’s closing band stays non-deductibleService Public, while interest at or below it remains a deductible financial chargeService Public. The page was otherwise refreshed with a « Vérifié le 16 octobre 2026 » stamp.

The reference rate itself equals the annual average of the average effective rates charged by credit institutions for variable-rate loans to businesses with an initial term over two years, with quarterly values set by the direction générale du Trésor and published in the « avis divers » of the Journal officiel; the deduction limit applies under the 3° of paragraph 1 of article 39 of the code général des impôts (CGI), as detailed in BOI-BIC-CHG-50-50-30.

Legal basis: article 39, 1-3° of the code général des impôts and BOI-BIC-CHG-50-50-30 on the limiting interest rate for partners' advances.

For a year closing between 30 September and 30 December 2026, apply the new cap matching the closing band (4.40 %, 4.43 % or 4.45 %) and leave non-deductible the part of shareholder interest above it.

Sources