I. – In the event of a transfer for valuable consideration of all or part of the settlor’s rights representing the assets or rights transferred into the trust assets which are not entered on the balance sheet of a company, the results of the trust assets are determined, on the date of the transfer, in accordance with the conditions set out in articles 201 et seq and taxed in the name of the transferor in accordance with the rules set out in article 238 quater N.
The difference between the transfer price and the acquisition price of these rights has no impact on the transferor’s taxable income.
II. – I also applies in the event of the death of the settlor, the termination or cancellation of the trust transaction or when it is terminated.