The Principle and Its Limits
Article L. 145-33 of the Code de commerce establishes that the renewed or revised rent must correspond to market rental value. In practice, this is substantially attenuated by the rent-capping rules of Article L. 145-34 — market value is only directly applied where those capping rules permit derogation (uncapping). Nonetheless, the court must always determine market rental value, even where the cap applies, because the value is needed as the reference for the capping calculation. The five criteria are identical for both revision and renewal proceedings.
Surface Area Weighting Methodology
The weighted area (surface pondérée) is calculated by applying coefficients to different portions of the premises, reflecting their actual value to the commercial operation. The main zone method for high-street retail assigns 100% to the primary zone (typically the first 20m from the shop front), then progressively reduces the coefficient for deeper zones and service areas.
| Zone / Area type | Typical coefficient |
|---|---|
| Main zone (front portion of retail ground floor) | 1.00 |
| Second zone | 0.80 |
| Third zone | 0.60 |
| Ancillary areas attached to the premises | 0.20–0.40 |
| First floor accessed via mall (shopping centre) | 1.00 |
| First floor accessed only via the shop | 0.50 |
| Mezzanine (structural) | 0.40 |
| Peripheral retail / retail parks — ground floor | 1.00 |
| Peripheral retail — ancillary attached surfaces | 0.20 |
| Outdoor display areas | 0.10–0.30 |
A contractually agreed weighting is binding for the period it covers but does not bind the judge in a later renewal — a prior weighting has no res judicata effect for a subsequent proceeding (CA Paris, 19 November 2008).
Upward and Downward Adjustments
| Upward adjustments (typical %) | Downward adjustments (typical %) |
|---|---|
| Enclosed terrace on public highway: +2–15% | Grosses réparations (Art. 606) borne by tenant: −5–10% (only pre-November 2014 leases) |
| Authorised subletting: +2–5% | Compliance works borne by tenant: −5–10% (excluding monovalent premises) |
| Broad permitted use / "all activities": +5–10% (up to 10%) | Taxe foncière borne by tenant: deducted at flat rate or actual amount (mandatory regardless of market practice) |
| Free assignment of lease right without landlord's consent: +2–5% | Building insurance premiums borne by tenant: deducted at actual amount |
| Combined "all activities" + free assignment: cumulative effect (~+30%) | Management fees borne by tenant: −5% or actual |
| Accession of tenant works in favour of landlord at end of tenancy: −10–20% |
A systematic abatement for property tax must be applied even where the market comparables used are all leases that also transfer the property tax to the tenant. The Court of Cassation has confirmed this in successive rulings through to February 2024 (Cass. 3e civ., 8 February 2024, n° 22-24.268). This position regularly meets resistance from shopping centre landlords — it remains the binding rule.
- Five criteria are exhaustive (Art. L. 145-33): courts and experts cannot consider factors outside them. Applied identically for revision and renewal proceedings. Market value must be determined even where the capping rule means it is not directly applied as the final rent.
- Criterion 1 — Premises characteristics (Art. R. 145-3): surface area; maintenance assessed on the premises themselves, fault is irrelevant (Cass. 3e civ., 17 Sept. 2008). Tenant's works assessed through the accession clause — end-of-tenancy accession means works are excluded from the assessment throughout the tenancy.
- Criterion 3 — Obligations (Art. R. 145-8): property tax transferred to tenant = mandatory downward adjustment regardless of market practice (Cass. 3e civ., 8 Feb. 2024). Same for building insurance and management fees. Broad permitted use and free assignment = upward adjustments. Art. 606 grosses réparations: only a downward factor for pre-November 2014 leases.
- Surface weighting: main zone 1.00; coefficients reduce for deeper and ancillary areas. Contractually agreed weighting is binding for the current lease only — no res judicata for the next renewal (CA Paris, 19 Nov. 2008).
- Comparables (Criterion 5): expressed per m² per year HT HC; same type, comparable location and activity. Paris CA generally refuses decapitalisation of key money. Only fixed floor rent appropriate for comparison in turnover leases.
Whether you are a landlord or tenant preparing for a renewal or revision proceeding, or challenging an expert report that has applied the wrong methodology, we advise on the application of each criterion and on the adjustment factors that are most frequently disputed.
Book a ConsultationThis article is for general information and educational purposes only. It does not constitute legal advice and does not create a lawyer-client relationship. Laws and regulations may have changed since publication. Always seek qualified French legal advice on market rental value in a French commercial lease.
Key Legal References
The five statutory criteria for market rental value — exhaustive list
Implementation regulations: premises (R. 145-3), destination (R. 145-4), commercial factors (R. 145-6), obligations (R. 145-8)
State of maintenance: assessed on the premises themselves; fault for deterioration is irrelevant
End-of-tenancy accession clause: tenant’s works excluded from rental value assessment throughout the tenancy
Accession deferred where restoration option is exercisable only on departure
Taxe foncière transferred to tenant: mandatory downward adjustment even where all comparables also transfer it
Contractually agreed surface weighting: binding for current lease only; no res judicata for next renewal
