Shareholder loan
Sums lent by a shareholder to their company; they may be repaid or incorporated into the capital.
Please note.This definition is deliberately simplified. It does not constitute legal or tax advice. The exact conditions, thresholds, rates and periods depend on your situation and on the regulations in force.
Which text applies?
- Art. 39, 1-3° of the French Tax Code (CGI) : Interest paid to shareholders on sums they leave or make available to the company, in addition to their share of the capital, is deductible up to a rate equal to the annual average of the effective average rates charged by credit institutions and financing companies on variable-rate loans to businesses with an initial term of more than two years, provided the capital is fully paid up.
- Art. L. 136-3, II, 2° of the French Social Security Code : For self-employed persons working in a company subject to corporate tax, the portion of dividends above 10% of a reference amount made up of the share capital, including share premium, and the sums recorded as shareholder loans (comptes courants d’associés) falls within the base for social security contributions.
How it works
A shareholder loan is an advance from the shareholder to the company, recorded in a current account (compte courant d’associé) and separate from the capital contribution. It often funds an acquisition, works or a cash need. An agreement usefully sets its term, its remuneration and, where relevant, its blocking, in particular where a bank makes this a condition of its financing.
Interest
The company may pay interest on the shareholder loan. The interest is deductible from its profit up to the rate under article 39, 1-3° of the CGI, published by the tax authorities; for a twelve-month financial year ending on 31 December 2025, this rate is 4.55%. The deduction requires the capital to be fully paid up.
For a shareholder who is an individual, the interest is fixed-income investment income. Received since 1 January 2026, it bears 31.4% in principle (12.8% income tax and 18.6% social security charges), unless the progressive scale is elected.
Dividends of a self-employed shareholder
Where the shareholder is a self-employed person working in the company, such as the majority manager of a SARL or a SELARL, their dividends above 10% of the capital, share premium and shareholder loans fall within the base for social security contributions. A shareholder loan therefore increases the portion of the dividends that remains subject only to the charges on investment income.
How does the rule apply? A worked example
The 10% threshold and the shareholder loan
Illustrative example: the majority manager of a company subject to corporate tax, who is self-employed, holds the whole of a €10,000 share capital, with no share premium, and has lent €190,000 to the company as a shareholder loan. The company pays them €50,000 in dividends.
- Reference amount (€10,000 + €190,000)
- €200,000
- 10% threshold
- €20,000
- Dividends subject to social security contributions
- €30,000
- For comparison, without a shareholder loan (threshold of €1,000)
- €49,000
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