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In 2024, France counted 13,335 millionaires who paid ZERO income tax.

This is yet another example of why we need a UN Tax Convention to fix global tax rules and finally make the super-rich pay their fair share, so there is real money for public services, climate action, and a green transition, instead of more loopholes for extreme wealth.

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There are ways to make your income a little bit smaller, but anyone who has actually zero income is obviously either unemployed or a retiree, and if they're a "millionaire", the most likely way that they would be is they have a 1mn+€ house, so almost certainly a retiree...

Is a 'holding' a term of art in french tax code, or do you just mean a holding company?

If french tax law works anything like us tax law, then in this case the rent income would be taxed as the millionaire's income. The taxes would just be differed until the millionaire actually took an equity disbursement from the holding company, thus generating reportable income.

Except with the difference that the year the rent was put on the books of the holding company, it would also be taxed as corporate profit.