Distributions made by the sociétés unipersonnelles d’investissement à risque mentioned in Article 208 D are exempt from income tax and, unless they are paid in an uncooperative State or territory within the meaning of article 238-0 A other than those mentioned in 2° of 2 bis of the same article 238-0 A, from the withholding tax mentioned in 2 of article 119 bis when the following conditions are met:
1° They are deducted from profits exempt from corporation tax pursuant to the provisions of Article 208 D;
2° The shareholder is domiciled for tax purposes in France or in a country or territory that has concluded an administrative assistance agreement with France with a view to combating tax evasion and avoidance;
3° The shares giving entitlement to the distributions concerned were subscribed by the initial sole shareholder or transferred free of charge following the death of that shareholder.