When you lend money to your SCI through a compte courant d’associé (CCA), one question comes up almost immediately: can you charge interest on that loan — and if so, how is it taxed?
The answer depends on whether your SCI is taxed under income tax (IR) or corporate tax (IS), the interest rate you choose, and how the funds were used. Get it right and you have a tax-efficient financing tool. Get it wrong and you could face a tax reassessment.
This article breaks down the rules, the current rate limits, and the tax treatment on both sides — for the SCI and for you as the lending associate.
This is the third article in our CCA series. If you’re new to the topic, start with What Is a Compte Courant d’Associé in a French SCI?.
Quick Reference: CCA Interest at a Glance
| Topic | Key Rule |
|---|---|
| Can you charge interest? | Yes — rate is freely agreed between the associate and the SCI |
| SCI à l’IR — Deductibility | Deductible if funds linked to property acquisition, conservation, or improvement (Art. 31 CGI) |
| SCI à l’IS — Rate cap | Max deductible rate = TEM average (4.55% for FY 2025). Capital must be fully paid up (Art. 39 CGI) |
| Tax on the associate | PFU flat tax of 31.4% (French tax residents); treaty withholding tax (non-residents) |
| Non-remunerated CCA | IR: no deemed interest (CE 2025). IS: risk of deemed interest reintegration |
Can You Charge Interest on a CCA?
Yes. French law gives associates and the SCI full contractual freedom when it comes to CCA remuneration. You can agree to lend money interest-free, or you can set an interest rate — the amount is determined freely between the parties.
In practice, most CCAs are structured as interest-bearing loans (prêts à titre onéreux). The interest rate and terms are set in a written agreement — either in the SCI’s statuts or in a separate CCA convention — and the CCA must show a positive (creditor) balance for the associate to receive interest.
Key point: There is no legal minimum or maximum interest rate for a CCA in an SCI. However, fiscal rules limit how much of that interest the SCI can deduct from its taxable income, as we’ll see below.
Source: Fascicule E-75, §3 — Rémunération du CCA (JurisClasseur Sociétés Formulaire, Marie-Antoinette Coudert, September 2025)
SCI Taxed Under Income Tax (IR): When Is CCA Interest Deductible?
Most French SCIs default to income tax (impôt sur le revenu). Under this regime, the SCI itself doesn’t pay tax — rental income flows through to the associates and is taxed as revenus fonciers (property income) on their personal returns.
The Rule: Article 31 of the CGI
For an SCI à l’IR, CCA interest is deductible from the SCI’s rental income under the same rules as bank loan interest. Article 31, I, 1°, d of the Code Général des Impôts allows the deduction of interest on debts contracted for:
- The conservation of the property
- The acquisition of the property
- The construction, repair, or improvement of the property
This means that if the associate’s CCA funds were used to buy, renovate, or maintain the SCI’s property, the interest paid on that CCA is deductible from the SCI’s revenus fonciers — just like mortgage interest from a bank.
The Catch: You Must Prove the Link
The SCI must be able to demonstrate a sufficient correlation between the remunerated CCA balance and the amounts actually used for the property-related purposes listed in Article 31. If the CCA funds were used for something else — or if the CCA balance far exceeds the property-related expenditure — the tax authorities can deny the deduction.
For example, if an associate lends the SCI 300,000 euros via CCA but the property only cost 200,000 euros and required no renovation, charging interest on the full 300,000 euros would raise questions. The interest deduction would likely be limited to the portion that corresponds to the property acquisition.
When CCA Interest Is Not Deductible (IR)
CCA interest is not deductible from revenus fonciers when:
- The funds cannot be linked to property acquisition, conservation, construction, repair, or improvement
- The CCA was used to balance the SCI’s cash flow in a way that goes beyond the property’s needs (e.g., annual loan repayments far exceeding rental income, while the CCA balance is far larger than the works actually financed)
In these cases, the interest is still owed to the associate under the CCA agreement, but it cannot reduce the SCI’s taxable property income.
Source: Fascicule E-75, §4 — Déductibilité des intérêts versés à un associé personne physique; Article 31, I, 1°, d du CGI; CE, 7e et 9e ss-sect., 8 juill. 1988, n° 64902
SCI Taxed Under Corporate Tax (IS): The Rate Cap
If your SCI has opted for corporate tax (impôt sur les sociétés), a different set of rules applies. CCA interest is deductible from the SCI’s taxable profit, but only up to a maximum rate set by the tax authorities each year.
Article 39, 1-3° of the CGI
This article sets two conditions for full deductibility of CCA interest in a company subject to IS:
- The SCI’s share capital must be fully paid up (libération intégrale du capital). If any associate still owes part of their capital contribution, CCA interest deductibility may be challenged.
- The interest rate must not exceed the annual average of the taux effectif moyen (TEM) — the average effective rate charged by French credit institutions on variable-rate business loans with an initial duration exceeding two years.
Any interest paid above the TEM ceiling must be added back to the SCI’s taxable result (réintégration extracomptable). The associate still receives the full interest, but the SCI loses the tax deduction on the excess.
Current TEM Rates (2025-2026)
The TEM is published quarterly and varies based on when your fiscal year ends:
For fiscal years closing on 31 December 2025: The maximum deductible rate is 4.55%, calculated as the average of the four quarterly rates for 2025:
| Quarter | TEM Rate |
|---|---|
| Q1 2025 | 4.92% |
| Q2 2025 | 4.60% |
| Q3 2025 | 4.36% |
| Q4 2025 | 4.30% |
| Annual average | 4.55% |
This is a notable decrease from the 5.97% rate that applied for fiscal years closing on 31 December 2023 and the 5.75% for 31 December 2024 closures.
For fiscal years closing in early 2026, the rate continues to trend downward — expect figures in the 4.30% to 4.50% range depending on your exact closing date.
Sources: LégiFiscal — Comptes courants d’associés: 4,55% pour les clôtures au 31 décembre 2025; BOI-BIC-CHG-50-50-30 (bofip.impots.gouv.fr); Article 39, 1-3° du CGI
Practical Example
Your SCI (IS) has share capital of 1,000 euros (fully paid up). Associate A has a CCA balance of 200,000 euros, and the CCA convention sets an interest rate of 6%.
- Interest charged: 200,000 × 6% = 12,000 euros
- Maximum deductible (at 4.55%): 200,000 × 4.55% = 9,100 euros
- Non-deductible excess: 12,000 − 9,100 = 2,900 euros (added back to taxable profit)
The associate receives the full 12,000 euros, but the SCI can only deduct 9,100 euros from its taxable result.
How Is CCA Interest Taxed for the Associate?
For French tax resident associates, regardless of whether the SCI is under IR or IS, the interest received is classified as revenus de capitaux mobiliers (investment income) and is subject to the prélèvement forfaitaire unique (PFU), commonly known as the flat tax.
Non-resident associates: the PFU is a domestic French regime and does not apply to non-residents. If you are tax-resident outside France, CCA interest paid to you by the SCI is subject to withholding tax (retenue à la source) at the rate set by the double tax treaty between France and your country of residence. Under most French treaties, interest withholding is capped at 10–15%, though some treaties reduce it to 0%. Check your specific treaty or ask your tax advisor.
The PFU Rate (2026)
Since 1 January 2026, the PFU rate is 31.4%, broken down as follows:
| Component | Rate |
|---|---|
| Income tax (impôt sur le revenu) | 12.8% |
| Social contributions (prélèvements sociaux) | 18.6% |
| Total PFU | 31.4% |
Important update: The PFU rate increased from the previous 30% due to a rise in social contributions enacted in the 2026 Social Security Finance Law (Loi de financement de la sécurité sociale pour 2026). A new contribution financière pour l’autonomie raised the CSG-equivalent rate on investment income from 9.2% to 10.6%, bringing total social contributions from 17.2% to 18.6%.
Note: This higher social contribution rate applies specifically to revenus de capitaux mobiliers (including CCA interest). Rental income (revenus fonciers) retains the previous 17.2% social contribution rate.
The Progressive Scale Option
Instead of the flat PFU, associates can opt to have their CCA interest taxed under the progressive income tax scale (barème progressif). This option must be elected annually when filing the tax return and applies to all investment income for that year — you cannot cherry-pick.
This option may be beneficial if the associate’s marginal tax rate is below 12.8%, which is the case for taxpayers in the 0% or 11% brackets. For most investors, the PFU is simpler and often more favourable.
Sources: Article 125 A du CGI; Loi de financement de la sécurité sociale 2026; Service-public.fr — Évolution du taux du PFU
When the Associate Is a Company
If the associate receiving CCA interest is itself a company (e.g., a holding structure), the interest is included in the company’s taxable profit and taxed under its own corporate tax regime — not via the PFU.
What About Non-Remunerated CCAs?
Not all CCAs carry interest. When an associate makes an interest-free advance to the SCI, different rules come into play depending on the SCI’s tax regime.
SCI à l’IR
A March 2025 ruling by the Conseil d’État (CE, 9e et 10e ch., 12 mars 2025, n° 474824) confirmed that in an SCI with no commercial activity, sums credited to a non-remunerated CCA do not constitute financial assistance (aides à caractère financier) within the meaning of Article 39, 13 of the CGI. In other words, the associate does not need to declare any imputed income — and there is no deemed interest to report.
SCI à l’IS
If the SCI has opted for corporate tax, interest-free CCAs fall under the framework of Article 39, 13 of the CGI, which governs interest-free loans between related entities. The tax authorities may impute a deemed interest rate and require the SCI to reintegrate the “lost” interest income into its taxable result. This is more likely when the associate holds significant control over the SCI.
Source: Fascicule E-75, §10-11; CE, 12 mars 2025, n° 474824, sté civile Saint-Louis
Practical Tips
Document everything. Keep a written CCA convention specifying the interest rate, payment terms, and the purpose of the funds. In case of a tax audit, you’ll need to show the link between the CCA and the property investment.
Watch the TEM each year. If your SCI is under IS, check the published TEM rate before setting or renewing your CCA interest rate. Setting a rate above the ceiling means the excess isn’t deductible.
Don’t forget the capital condition. For SCI à l’IS, CCA interest is only deductible if the share capital is fully paid up. If your SCI has uncalled capital, resolve this before paying interest on CCAs.
Consider the full tax picture. While CCA interest is deductible for the SCI (under the right conditions), it’s taxable income for the associate at 31.4% (PFU). Compare this with other ways to extract value from the SCI — dividends, management fees, or rent — to find the most tax-efficient approach for your situation.
SCI à l’IR: prove the property link. The deductibility of CCA interest in an SCI à l’IR hinges entirely on demonstrating that the funds were used for property acquisition, conservation, or improvement. Keep clear accounting records showing exactly how CCA advances were deployed.
Frequently Asked Questions
Is there a legal maximum interest rate for a CCA in an SCI?
No. The interest rate on a CCA is freely agreed between the associate and the SCI. However, for SCIs subject to corporate tax (IS), only interest up to the annual TEM ceiling (4.55% for fiscal years closing 31 December 2025) is tax-deductible. Any excess is added back to the SCI’s taxable profit.
Can CCA interest be deducted from rental income in an SCI à l’IR?
Yes, but only if the CCA funds were used for property-related purposes — acquisition, conservation, construction, repair, or improvement. The SCI must be able to demonstrate a clear link between the borrowed funds and the property expenditure. If the funds were used for other purposes, the interest is not deductible from revenus fonciers.
What is the current flat tax (PFU) rate on CCA interest received by an associate?
Since 1 January 2026, CCA interest is taxed at a PFU rate of 31.4% (12.8% income tax + 18.6% social contributions). This is up from the previous 30% rate, following a 1.4-point increase in social contributions enacted in the 2026 Social Security Finance Law. Associates can alternatively opt for the progressive income tax scale if their marginal rate is below 12.8%.
What happens if I lend money to my SCI interest-free?
For an SCI à l’IR, a 2025 Conseil d’État ruling confirmed that non-remunerated CCAs in a non-commercial SCI do not trigger deemed interest — the associate has nothing extra to declare. For an SCI à l’IS, however, the tax authorities may impute a deemed interest rate under Article 39, 13 of the CGI and require the SCI to add this “lost” income back to its taxable result.
Does the SCI’s share capital need to be fully paid up for CCA interest to be deductible?
For SCIs under corporate tax (IS), yes. Article 39, 1-3° of the CGI requires that the share capital be fully paid up (libération intégrale du capital) before CCA interest can be deducted. If any associate still owes part of their capital contribution, the deductibility may be challenged. This condition does not apply to SCIs under income tax (IR).
Key Takeaways
CCA interest in a French SCI is a flexible financing tool, but the tax treatment varies significantly between IR and IS regimes. For SCIs under income tax, the key question is whether the funds were used for property purposes (Article 31 of the CGI). For SCIs under corporate tax, the interest rate must stay within the annual TEM ceiling (4.55% for 2025) to be fully deductible (Article 39, 1-3° of the CGI). On the associate’s side, interest income is taxed at the PFU rate of 31.4% since 2026 for French tax residents (up from the previous 30%), or at treaty withholding tax rates for non-residents.
Understanding these rules before setting your CCA terms can save you from unpleasant surprises at tax time.
Related Posts You Should Read
- The Ultimate Guide to the Compte Courant d’Associé in a French SCI – The complete overview of shareholder current accounts, including how they work and their strategic uses.
- Can a French SCI Block Reimbursement of a Compte Courant d’Associé? – What happens when the SCI tries to delay or refuse repayment of your current account.
- Your Right to Get Your Money Back at Any Time – The legal protections ensuring associates can withdraw their current account loans on demand.
- Compte Courant vs Capital in a French SCI – The key differences between lending to your SCI and investing as capital, and when to use each.
- How to Create a SCI in France – Step-by-step guide to setting up your French property company, including the statutes that govern current accounts.
- SCI Accounting: What Every Property Investor Needs to Know – How current account interest and balances appear in your SCI’s financial statements.
