Since the taxation of 2025 income, households with the highest incomes may owe a differential contribution on high incomes (CDHR), which aims to ensure a minimum tax of 20%. Holders of cryptocurrencies are directly concerned: a large gain, taxed under the flat tax at 12.8% income tax, may push them over the thresholds.
This article presents the CDHR, how it is calculated, the question of gains on cryptocurrencies and the December instalment, with a worked example. Each situation deserves to be analysed, ideally with a lawyer, preferably before the end of the year.
In brief
- The CDHR aims at a minimum tax of 20% for households whose reference tax income exceeds €250,000 (single person) or €500,000 (couple); only French tax residents are in principle concerned.
- Introduced for 2025 income, it was extended by the 2026 Finance Act until the public deficit falls back below 3% of GDP.
- It is in principle equal to the difference between 20% of the income taken into account and the tax already due (income tax, CEHR, etc.), after certain increases and a reduction mechanism.
- Exceptional income is only taken into account for a quarter of its amount; a large gain on cryptocurrencies may, depending on the case, fall within this concept.
- An instalment equal to 95% of the estimated contribution is in principle paid between 1 and 15 December of the income year, with a surcharge in the event of non-payment or underpayment.
Contents
What is the CDHR?
The differential contribution on high incomes is added to income tax and to the exceptional contribution on high incomes (CEHR). It concerns taxpayers who are tax-domiciled in France and whose reference tax income, adjusted under specific rules, exceeds €250,000 for a single person or €500,000 for a couple taxed jointly. Non-residents are in principle not subject to it.
Created by the 2025 Finance Act for 2025 income only, it was extended by the 2026 Finance Act until the public deficit falls back below 3% of gross domestic product. For 2026 income and subsequent years, the 2026 Finance Act adjusted its calculation, in particular so that only a quarter of the CEHR relating to exceptional income is taken into account and so that certain tax reductions, such as the one for donations, are neutralised.
How is the CDHR calculated?
The CDHR is in principle equal to the difference, if positive, between:
- on the one hand, 20% of the adjusted reference tax income, in which exceptional income is only included for a quarter of its amount;
- on the other hand, the sum of income tax, the CEHR and certain final withholding taxes, increased by €12,500 for a couple taxed jointly and by €1,500 per dependant.
A reduction mechanism lowers the contribution for households whose adjusted income remains close to the threshold:
| Situation | Adjusted income concerned | Amount used instead of 20% of income |
|---|---|---|
| Single person | Up to €330,000 | 82.5% of the portion of adjusted income above €250,000 |
| Couple taxed jointly | Up to €660,000 | 82.5% of the portion of adjusted income above €500,000 |
Gains on cryptocurrencies: exceptional income?
Exceptional income is income which, by its nature, is not likely to be received every year and whose amount exceeds the average net income of the previous three years. It is only taken into account for a quarter of its amount, which can prevent one-off income from pushing a household over the CDHR threshold on its own.
A gain made on a one-off basis by an individual on cryptocurrencies appears capable of falling within this concept, but its characterisation depends on the facts and is not certain in every case. It would in principle not apply to gains from a professional activity, taxed in another category (see the article on the line between individual and professional).
A worked example
Paul, single, a French tax resident with no other significant income, makes a gain of €900,000 on cryptocurrencies in 2025, taxed under the flat tax. The calculation is simplified (no reduction, dependant or other income):
| Item | If the gain is not exceptional income | If it is exceptional income |
|---|---|---|
| Income taken into account for the CDHR | €900,000 | €225,000 (a quarter) |
| €250,000 threshold exceeded? | Yes | No |
| 20% of the income taken into account | €180,000 | — |
| Less income tax (12.8% of €900,000) | − €115,200 | — |
| Less the CEHR (3% × €250,000 + 4% × €400,000) | − €23,500 | — |
| CDHR | €41,300 | €0 |
What is at stake in the characterisation can therefore be significant. It deserves to be examined before the December instalment is paid, ideally with a lawyer.
The December instalment
An instalment equal to 95% of the estimated CDHR is in principle paid between 1 and 15 December of the year in which the income is received (in December 2025 for 2025 income, in December 2026 for 2026 income), on the basis of income received up to 1 December and an estimate of December income. A 20% surcharge in principle applies in the event of non-payment or late payment, or where the instalment paid is more than 20% below the expected amount. The balance is paid with the following year’s income tax.
CDHR and CEHR: what are the differences?
| Criterion | CEHR | CDHR |
|---|---|---|
| Purpose | Additional contribution of 3% or 4% on the portion of income above the thresholds | Minimum tax of 20% of adjusted income |
| Thresholds | €250,000 (single person) or €500,000 (couple) | €250,000 (single person) or €500,000 (couple) |
| Persons concerned | Taxpayers taxable in France, including, depending on the case, non-residents | In principle, French tax residents only |
| Duration | Permanent | Until the public deficit falls back below 3% of GDP |
The CDHR combines several technical concepts: adjusted income, exceptional income, reduction mechanism, instalment. Its effects on a large gain can be significant, and the CEHR comes on top. An analysis with a lawyer, preferably before the end of the year, generally makes it possible to estimate the contribution and the instalment.
FAQ
Who is concerned by the CDHR?
In principle, households tax-domiciled in France whose adjusted reference tax income exceeds €250,000 for a single person or €500,000 for a couple, and whose tax remains below 20% of that income.
Does a large gain on cryptocurrencies necessarily trigger the CDHR?
No. If it is exceptional income, it is only taken into account for a quarter of its amount, which may keep the household below the threshold. Its characterisation depends on the facts and deserves to be analysed.
Does the CDHR apply to non-residents?
In principle no: only taxpayers tax-domiciled in France are subject to it. Non-residents may, however, depending on the case, be liable for the CEHR.
When is the instalment paid?
In principle between 1 and 15 December of the year in which the income is received, for 95% of the estimated contribution; the balance is paid the following year with income tax.
Is the CDHR temporary?
It was extended by the 2026 Finance Act until the public deficit falls back below 3% of gross domestic product.
Read more
- Exchanging crypto for stablecoins: taxable from 2027?
- Crypto-assets and DAC 8: letters from the tax authorities as early as the end of 2027?
- Exceptional Contribution on High Incomes (CEHR): Calculation, Smoothing and Examples
- How to Declare Your Cryptocurrencies?
- Cryptocurrency Taxation
- Crypto Taxes: Individual or Professional, Where Is the Line?
- Cryptocurrency Taxation (Made Easy) in Questions and Answers
