The tax and social security regime applicable to gains from free share allocations (FSA)

November 27, 2025

In February 2025, the regime applicable to gains from management packages, including the tax regime applicable to free share allocations (AGA), was substantially amended (Law No. 2025-127 of February 14, 2025, introducing Article 163 bis H of the CGI).

The tax authorities have provided further details on the application of the provisions of Article 163 bis H affecting this tax regime for free share allocations. The result is a rather complex regime, which can be better understood with the help of the following presentation.