Assets held in an account held abroad, within the meaning of the second paragraph of article 1649 A, or in a capitalisation contract or an investment of the same nature subscribed abroad, within the meaning of article 1649 AA, and whose origin and acquisition methods have not been justified under the procedure provided for in Article L. 23 C of the Book of Tax Procedures are deemed to constitute, in the absence of proof to the contrary, assets acquired free of charge which are subject, on the date of expiry of the periods provided for in the same Article L. 23 C, to gratuitous transfer duties at the highest rate mentioned in Table III of Article 777.
These duties are calculated on the highest value known to the administration of the assets held in the account or contract over the ten years preceding the sending of the request for information or justification provided for in article L. 23 C of the tax procedures book, less the value of the assets whose origin and acquisition methods have been justified.
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