La Fidal (Fédération des Promoteurs immobiliers de France) vient de publier une étude sur la fiscalité immobilière applicable dans divers pays européens. La comparaison démontre que le cumul des différentes impositions pèse de manière élevée en France sur les prix de vente du résidentiel neuf.
Pour les taxes indirectes (TVA et différentes taxes liées au dépôt du permis de construire) frappant le cycle de production de l’immeuble, la France présente incontestablement le niveau d’imposition le plus élevé du fait de la conjugaison d’une TVA au taux de 20% appliquée au prix de vente de l’immeuble et des diverses autres taxes indirectes représentant quant à elles de 3% à 4% du prix de vente.
Le pays avec la fiscalité la plus favorable est le Royaume-Uni, avec un écart de fiscalité de 12% à 13% du prix de vente d’un appartement neuf en comparaison avec la France, soit un écart de fiscalité d’environ 24.000 euros / 26.000 euros lors de l’acquisition d’un appartement neuf d’un prix de 200.000 euros HT par un particulier.
Les pays européens autres que l’Angleterre ont une fiscalité plus favorable que la France avec un avantage financier pour ces autres pays compris entre 3% et 7% du prix de vente, soit un avantage financier compris entre 6.000 euros et 14.000 euros dans le cas de la vente d’un appartement neuf de 200.000 euros HT. Il existe toutefois une exception, celle des Pays-Bas qui bénéficient d’une imposition certes plus favorable qu’en France mais avec un avantage fiscal limité à seulement 1% du prix de vente. Il doit toutefois être précisé que le mécanisme de déduction des frais financiers du revenu global applicable aux Pays-Bas permet à ce pays d’avoir une fiscalité nettement plus attractive que la France sur l’acquisition de résidentiel pendant la période de détention de l’appartement.
La France a là encore la fiscalité la plus élevée en matière d’impôts locaux (taxe foncière et taxe d’habitation). Notre pays a également le niveau d’imposition le plus élevé pour l’impôt sur le revenu dans le cadre d’un investissement locatif hors régime Pinel, seul le Royaume-Uni ayant un régime d’imposition des loyers proche de celui de la France. La Belgique, l’Espagne et les Pays-Bas ont une imposition très nettement inférieure à la France en la matière.
Enfin, s’agissant des plus-values sur la cession d’une résidence principale et des droits de donation/succession, la France a un régime d’imposition comparable à celui des autres pays étudiés, les cas d’exonération de plus-value sur résidence principale étant similaires à ceux des autres pays. C’est là le seul élément d’imposition pour lequel la France n’est pas pénalisé, même si le régime français n’est pas pour autant plus favorable que celui des autres principaux pays européens.
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