The assets mentioned in article 965 placed in a trust defined in article 792-0 bis are included, for their net market value on 1st January of the tax year, as the case may be, in the assets of the settlor or in those of the beneficiary who is deemed to be a settlor pursuant to II of the same article 792-0 bis.
The first paragraph of this article does not apply to irrevocable trusts whose sole beneficiaries fall under article 795 or are organisations of the same kind covered by article 795-0 A and whose director is subject to the law of a State or territory that has entered into an administrative assistance agreement with France to combat tax evasion and avoidance.
The French Tax Code, CGI.