Question 11505 — income tax

Summary

Mr. Hubert Brigand draws the attention of the Minister of Action and Public Accounts to the consequences of the reform of the non-professional furnished rental system (LMNP), introduced by article 24 of the finance law for 2025, for owners of accommodation located in para-hotel residences. Since this reform, the accounting depreciation deducted during the holding period must be reintegrated into the acquisition price for the calculation of the taxable capital gain, which leads to a significant increase in the taxable base in the event of transfer of the property. The legislator has, however, excluded from this mechanism several categories of service residences - notably student residences, senior residences and EHPADs - which are not subject to the reintegration of depreciation and thus maintain a tax regime more favorable to the resale. On the other hand, para-hotel residences, although operated in a professional manner and presenting characteristics similar to these service residences (management by a commercial operator, commercial lease with the owner, offer of para-hotel services), have not been included in the list of establishments benefiting from this exclusion. The owners concerned therefore find themselves in a less favorable than that of other categories of housing with comparable functioning. An amendment aimed at extending the exemption to para-hotel residences was tabled during the examination of the finance bill for 2026, but was not retained. Owners in the MP's constituency are concerned about the economic effects of this difference in treatment, likely to weaken the operating balance of these residences and discourage investment in this sector. Also, he asks him his intentions regarding a possible evolution of the system, in order to allow the integration of para-hotel residences in the field of exemptions provided for certain service residences or, at the very least, to examine the terms of a fairer tax treatment towards them.

Machine translation from French. The official text remains authoritative.

Timeline

1. 9 December 2025

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• Hubert Brigand · auteur

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