"I am buying a colleague's patient list, can I deduct the price?" "I do a lot of home visits, how do I deduct my car?" "Can I set up a holding company to reinvest?"
Physiotherapists (masseurs-kinésithérapeutes, or kinés) and other self-employed health professionals in France ask us these questions regularly, including those who trained abroad. Behind them lie tax choices that can weigh on a practice's profitability, growth and eventual sale. Some are made when you set up, others before buying a patient list or moving into a company. Here are the essentials, project by project.
In short
The first choice is your tax regime. The micro-BNC regime is simple, but its flat 34% allowance replaces all your actual expenses. When your expenses exceed that level, or when you buy a patient list, the actual-profit regime (déclaration contrôlée) is often more favourable.
Buying a patient list, travelling to patients, setting up in a rural area or sharing premises each open up specific deductions or exemptions, subject to conditions. Reinvesting through a holding company, on the other hand, first requires practising through a company.
These choices are made before the project, not when you file your tax return.
Micro-BNC or actual-profit regime, which should you choose?
The micro-BNC regime suits you as long as your actual expenses stay low. Beyond that, the actual-profit regime is often more attractive, but the comparison is worth putting into figures.
The micro-BNC regime applies automatically when your receipts, excluding VAT, for the previous year or the year before do not exceed €83,600, the threshold set for 2026 to 2028 (BOFiP). You therefore only leave it after two consecutive years above the threshold. In the year you set up, receipts are converted to a full year to assess the threshold for the following years (BOFiP).
Under micro-BNC, your taxable profit equals your receipts minus a flat 34% allowance, deemed to cover all your expenses. You deduct nothing else, not the rent of your practice, not your car, not your loan interest.
The actual-profit regime requires bookkeeping, often with a chartered accountant (expert-comptable), but it lets you deduct your actual expenses. It becomes attractive when your deductible expenses exceed 34% of your receipts, which happens quickly with rent, a vehicle, equipment or a loan. That benchmark is not enough on its own. You also need to factor in the cost of bookkeeping, how regular your expenses are from one year to the next, and their nature, since not all of them are deductible.
Take a physiotherapist who collects €80,000 in fees and bears €35,000 of deductible expenses, social contributions included. Under micro-BNC, they are taxed on €52,800, their receipts minus the 34% allowance. Under the actual-profit regime, they are taxed on €45,000. The €7,800 difference in taxable income should be weighed against the accountant's fees, and it widens in the year of a purchase, since only the actual-profit regime allows the amortisation of the patient list and the loan interest to be deducted.
You can opt for the actual-profit regime even below the threshold. It is also required to benefit from the rural-area exemption.
Buying a patient list or a practice, what can you deduct?
Loan interest and, for a patient list bought up to 2029, its amortisation, subject to conditions.
Buying a colleague's patient list (patientèle) means buying their right to introduce you to their patients. The contract is registered and bears duties calculated as for a business, nil up to €23,000, then 3% up to €200,000 and 5% above (impots.gouv.fr). If you buy into a practice company instead, duties are 3% after an allowance for shares in an SELARL-type company (parts sociales) and 0.1% for shares in an SELAS-type company (actions).
For a long time, the price of a patient list could not be amortised. For a patient list acquired between 1 January 2022 and 31 December 2029, a professional under the actual-profit regime can now deduct its amortisation (BOFiP). To do so, they must show that the patient list has a limited useful life, or qualify as a small business under the French Commercial Code, which most practices do, in which case amortisation runs over ten years.
This deduction is excluded when the patient list is acquired from a related business, or contributed by the practitioner to a company they control. Contributing your own patient list to your SEL therefore does not allow the company to amortise it. Interest on a loan financing a purchase is, for its part, deductible under the actual-profit regime.
Before buying a patient list, three checks
The tax treatment of the price. Have the price split between the patient list and the equipment, which is depreciated under its own rules, and have its justification checked, together with the clause preventing the seller from setting up again nearby.
Financing. Loan interest is deductible under the actual-profit regime. Buying in your own name or through a practice company does not have the same effects, either for the deduction or for a future holding company project.
Your tax regime. Micro-BNC allows neither amortisation nor interest to be deducted. The switch to the actual-profit regime is decided from the year of the purchase, and it is also a condition for the rural-area exemption.
Working with others without tax surprises
The fee (redevance) that an associate physiotherapist (collaborateur) pays the practice holder for the use of the premises and the patient list is not a treatment. According to the tax authorities, it is subject to VAT above the small business threshold (franchise en base), whereas amounts kept by the holder during an occasional locum are not (ministerial answer of 26 January 2021). A practice holder who takes on several associates should therefore monitor that threshold closely.
To share the costs of a group practice, the cost-sharing company (société civile de moyens, SCM) remains the classic tool. It pools rent, secretarial services or equipment without sharing fees, and each member deducts their share of the costs. To truly practise together and share profits, you need a practice company, an SCP or an SEL (Ordre des masseurs-kinésithérapeutes).
How can you deduct home visit travel?
With actual costs or the mileage scale, provided you are under the actual-profit regime and keep a record of your rounds.
The travel allowances you invoice are part of your receipts. On the other side, your professional travel expenses are deductible. For your car, you can choose between actual costs and the mileage scale for BNC professionals, which covers depreciation, maintenance, tyres, fuel and insurance in one go. Parking costs are added on top, as is loan interest if the vehicle is recorded as a business asset (BOFiP).
The mileage scale option applies for the whole year and to all your professional vehicles. If your vehicle is on long-term lease or lease-purchase (crédit-bail), there are two routes. You can deduct the lease payments and your other actual costs, with fuel then valued on a flat-rate basis. Or you can give up deducting the lease payments and apply the mileage scale. In all cases, log your rounds, with dates, addresses and mileage, as this is the first document requested in a tax audit.
An exemption for setting up in a rural area
The France Ruralités Revitalisation (FRR) scheme exempts self-employed professionals from tax on profits when they create or take over a practice in a listed municipality between 1 July 2024 and 31 December 2029 (BOFiP). The exemption is total for five years, then 75%, 50% and 25% over the following three years, within the EU ceiling for de minimis aid, which is €300,000 over three years. Buying the patient list of a departing colleague is treated as a takeover and may qualify.
The conditions are assessed when you set up, and a condition missing at that point cannot be remedied later. The practice must employ fewer than eleven staff and be under an actual-profit regime, which means opting for the actual-profit regime from the outset if you are under micro-BNC, except in municipalities listed as FRR+, where the tax regime does not matter. The practice and the activity must be located in the zone, with a limited tolerance. If more than 25% of your turnover is generated outside listed municipalities, for example during home visits, the exemption is reduced or lost depending on the case. In a practice company subject to corporate tax, it is the company that benefits from the exemption.
Some set-ups do not qualify (BOFiP). This is the case for a physiotherapist already established in a listed municipality who moves premises or joins a multidisciplinary health centre without changing municipality, for a locum already working in the municipality who becomes a practice holder there, and for a practitioner whose activity fell under another zone-based scheme, such as the former rural revitalisation zone (ZRR), during the previous five years. Taking over a practice within the seller's family is also restricted. When in doubt, the classification as a creation or a takeover should be secured before setting up, if necessary through a ruling request (rescrit).
Incorporating and reinvesting through a holding company
A physiotherapist practising in their own name cannot channel their fees into a holding company. To reinvest through a company, you must first practise through a professional practice company (société d'exercice libéral, SEL), whose shares a holding company for liberal professions can then hold. As a sole practitioner, your fees are subject to income tax, however much you leave in the practice account.
An SEL subject to corporate tax pays 15% on its first €42,500 of profit and 25% above, provided in particular that its share capital is fully paid up and at least 75% held by individuals, directly or through a holding company that itself meets these conditions. You pay yourself a remuneration, and the rest can be reinvested or distributed.
The holding company for liberal professions, called an SPFPL, holds the shares of the SEL. Subject to conditions, it receives dividends almost tax-free under the parent-subsidiary regime, then reinvests them. It can also borrow to buy out a partner's shares. We explain the advantages and limits of a holding company in our French-language article Faut-il créer une holding ?
Social contributions remain the key issue. Dividends received directly by a shareholder who practises in the SEL are subject to social contributions on the portion exceeding 10% of the share capital, share premiums and shareholder current account. In 2023, the Cour de cassation extended this treatment to dividends paid to a holding company, in an SEL where a single practitioner worked and whose sole shareholder was a holding company owned by that practitioner and their spouse (Cass. 2e civ., 19 October 2023, no. 21-20.366). The ministry stated in 2025 that this decision concerned a specific situation and had no general scope, particularly where several shareholders practise in the SEL (ministerial answer published in the JO Sénat of 27 February 2025). For a physiotherapist practising alone in their SEL, the structure should therefore be analysed before the holding company is set up.
Incorporation needs preparation. Contributing your patient list to the SEL can benefit from a tax deferral, but the company cannot then amortise it. The social cost, the choice between SELARL and SELAS and the timing are decided beforehand, with figures in hand. For the practice premises, a separate property company (SCI) keeps the real estate apart from the activity, with rent set at an arm's length level.
VAT, what is exempt and what is not
Treatments provided by a physiotherapist within their regulated profession, for a therapeutic or preventive purpose, are exempt from VAT (BOFiP). A medical prescription is not a condition, but it helps demonstrate that purpose.
Wellness massages, sports coaching, group fitness classes, product sales or associate fees are not treatments. These receipts fall within the scope of VAT without benefiting from the exemption. You do not have to charge VAT, however, as long as you benefit from the small business exemption, meaning as long as these receipts stay below €37,500 a year for services, your exempt treatments not being counted (BOFiP). If that threshold is exceeded, VAT becomes due, sometimes from the year it is exceeded. If you develop these activities, track them separately.
Preparing for retirement and the sale of your practice
Contributions to an individual retirement savings plan (plan d'épargne retraite, PER) are deductible from your profit within limits linked to your professional income. It is often the first lever to ease the tax burden in your highest-earning years.
On a sale, three capital gains exemption regimes may apply, each with its own conditions. The first fully exempts the gain if your average receipts do not exceed €90,000, and partially up to €126,000, provided in particular that you have practised for at least five years (Bpifrance Création). The second covers the transfer of a sole practice worth no more than €500,000, and partially up to €1,000,000, subject to conditions on the length of activity and on the seller not controlling the buyer (BOFiP). The third accompanies retirement, which must take place within two years before or after the sale.
The amounts are therefore not enough on their own. These regimes cannot all be combined, and the right choice depends on your situation. In an SEL, it is the sale of your shares that is taxed, under different rules. In all cases, a sale should be prepared two or three years ahead.
Are you planning to set up, buy a patient list, go into partnership, form an SEL or an SPFPL, or prepare the sale of your practice? Beaupère & Guermouche Avocats helps you analyse and secure the tax consequences of your project, in coordination with your accountant. We offer a free initial call to understand your situation and identify the points that call for in-depth analysis. The call can take place remotely or at our office, in French or in English.
Frequently asked questions
Can a physiotherapist amortise the purchase of a patient list?
Yes, for a patient list acquired between 1 January 2022 and 31 December 2029, provided you are under the actual-profit regime. For a practice that qualifies as a small business, amortisation runs over ten years. It is excluded if the patient list is acquired from a related business or if you contribute it to a company you control.
Can a physiotherapist under micro-BNC deduct car expenses?
No. The flat 34% allowance is deemed to cover all expenses, including the car. To deduct actual costs or apply the mileage scale, you must opt for the actual-profit regime.
Can you set up a holding company when practising in your own name?
A holding company cannot receive your fees. It can hold shares in a practice company, which means first practising through an SEL. In your own name, a property company (SCI) can, however, buy the practice premises and rent them to you.
Does an SPFPL avoid social contributions on dividends?
Not in every case. Dividends paid to the holding company are not, in principle, subject to the practitioner's social contributions. The Cour de cassation nevertheless subjected them to contributions in 2023, for an SEL where the practitioner worked alone and whose sole shareholder was their family holding company. The ministry stated in 2025 that this decision had no general scope, especially where several shareholders practise in the SEL.
Should you charge VAT to an associate physiotherapist?
On the associate fee, yes, according to the tax authorities, once your receipts subject to VAT exceed the small business threshold, set at €37,500 for services. Your exempt treatments are not counted.
Do these rules change if you trained outside France?
No. These tax rules depend on how you practise in France, not on where you trained. The right to practise in France is a separate matter, handled by the authorities in charge of authorisations to practise and by the Ordre des masseurs-kinésithérapeutes.
General information up to date as of 26 October 2026, which does not constitute legal advice. Each situation depends on your receipts, how you practise and your projects, and is assessed case by case.