Intermediate rental housing (LLI): 10% VAT, property-tax exemption, conditions
Intermediate rental housing (LLI, article 279-0 bis A of the French General Tax Code) grants 10% VAT instead of 20% on a new-build home in a high-demand zone, reserved to a legal entity, an SCI or family SARL, with at least 25% social housing in the scheme. A corporate-tax credit can cover property tax for 20 years.
A scheme reserved to a legal entity, open to individuals through a company
Intermediate rental housing (LLI) is based on article 279-0 bis A of the French General Tax Code (CGI), which applies a 10% VAT rate instead of 20% to the purchase price of a new-build home, under cumulative conditions on the tenant's income, the rent cap, the location, and the status of the beneficiary, who must be a legal entity. An individual therefore cannot invest in LLI directly.
Since the 2024 Finance Act, the scheme has been open to individuals, provided they invest through a company: an SCI taxed under income tax or corporate tax, or a family SARL.
Property tax: exemption or tax credit, depending on the completion date
For dwellings completed before 1 January 2023, the LLI scheme grants an exemption from property tax on built land (TFPB) for 20 years from the year following completion (article 1384-0 A of the CGI).
For dwellings completed from 1 January 2023, that is, for any new construction sold today, this mechanism is replaced by a corporate-tax credit equal to the property tax due, for 20 years (article 220 Z septies of the CGI). This text explicitly targets corporate tax: whether it applies to a transparent SCI under income tax is not confirmed by an official source and should be checked with a tax adviser before committing.
What is not an advantage specific to the LLI
The lower notary fees often advertised, around 2% to 3% of the price, are not specific to the LLI scheme: they come from the general tax treatment of any new-build or off-plan purchase, where the land-registration tax, about 0.715%, replaces the transfer duties of older property, 5.09% to 5.80%. A non-LLI new-build purchase would benefit from exactly the same lower fees.
The letting commitment often advertised at 15 to 20 years has no single explicit legal basis in article 279-0 bis A itself. The mechanism that genuinely constrains is the tapering VAT clawback of article 284, II bis of the CGI in the event the commitment is broken, calculated over 20 years, with tolerance for partial sales from the 11th year.
Frequently asked questions
Can an individual invest directly in LLI?
No. Article 279-0 bis A of the CGI requires the beneficiary to be a legal entity. Since the 2024 Finance Act, an individual can invest through an SCI taxed under income tax or corporate tax, or a family SARL, never directly.
What VAT rate applies to an LLI purchase?
10% instead of 20%, under cumulative conditions of zone (A, Abis, B1), rent and tenant-income caps, and a social mix of at least 25% social housing in the municipality or the scheme.
Does the property-tax exemption still apply to new-build homes?
Not in that form. Dwellings completed from 1 January 2023 no longer get an exemption but a corporate-tax credit equal to the property tax due, for 20 years (article 220 Z septies of the CGI), a mechanism whose application to an income-tax SCI still needs checking.
Are the lower notary fees an advantage of the LLI?
No. They come from the general regime for any new-build or off-plan purchase, land-registration tax being far lower than the transfer duties of older property, not a rule specific to the LLI.
How long must the property be let under LLI?
No single duration is set explicitly by article 279-0 bis A of the CGI. The structuring mechanism is the tapering VAT clawback of article 284, II bis of the CGI, calculated over 20 years, with tolerance for partial sales from the 11th year.
Read next
- Malraux scheme (VIR): what tax reduction for restoring an old building?
- The Jeanbrun scheme (private landlord status): depreciation, caps and conditions
- The Denormandie older-property scheme: tax reduction, works, eligible municipalities
- Rental income: should you choose the micro-foncier or the actual regime?
- BOFiP-Impôts : BOI-TVA-IMM-30 (opérations immobilières dans le secteur du logement intermédiaire)
- Légifrance : article 279-0 bis A du code général des impôts
- BOFiP-Impôts : BOI-IF-TFB-10-75 (exonération de taxe foncière, logements intermédiaires)
- Légifrance : article 220 Z septies du code général des impôts
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