For the assessment of corporation tax, no account shall be taken of a scheme or series of schemes which, having been put in place to obtain, as a principal objective or as one of the principal objectives, a tax advantage which runs counter to the object or purpose of the applicable tax law, are not genuine having regard to all the relevant facts and circumstances. A scheme may comprise several…
I.-For the purposes of this article and articles 205 C and 205 D, the following definitions shall apply: 1° Hybrid arrangement: a situation in which: a) A payment is made under a financial instrument in respect of which a) A payment made in respect of a financial instrument gives rise to a deductible expense in the State of residence of the debtor without being included in the taxable income in…
When a hybrid entity of a reverse hybrid scheme is incorporated or established in France, its income shall be taxed, as the case may be, either under corporation tax or under the conditions provided for in Article 8 of this Code, insofar as it is not taxed in another State. The first paragraph of this article shall not apply to undertakings for collective investment, such an undertaking being defined as…
When payments, expenses or losses deductible from the taxable income of a taxpayer who is resident in France and in another State pursuant to the rules of that State are taken into account in both States, their deduction is not allowed in France. However, this deduction is allowed in France when: 1° The payment, expense or loss likely to be the subject of a double deduction is included in the…
1. Subject to the provisions of Articles 8 ter, 239 bis AA, 239 bis AB and 1655 ter, sociétés anonymes, sociétés en commandite par actions, sociétés à responsabilité limitée that have not opted for the partnership tax regime under the conditions provided for in IV of Article 3 of Decree no. 55-594 of 20 May 1955 as amended, are liable for corporation tax, regardless of their purpose, cooperative societies and…
1. The following are exempt from corporation tax: 1° (provisions no longer applicable); 1° bis. Professional trade unions, whatever their legal form, and their unions for their activities relating to the study and defence of the rights and collective material or moral interests of their members or the persons they represent and provided that they operate in accordance with the provisions governing them; 2° Except for transactions carried out with…
Sont également exonérés de l’impôt sous réserve des dispositions de l’article 208 A : 1° (Abrogé à compter du 1er janvier 1993) ; 1° bis-Les sociétés d’investissement qui sont régies par les articles L. 214-127 et seq. of the Monetary and Financial Code, in respect of the portion of profits arising from the net proceeds of their portfolio or from capital gains realised on the sale of securities or shares…
The benefit of the provisions of 1° bis and 2° of article 208 is reserved for investment companies governed by articles L. 214-127 et seq. of the Monetary and Financial Code, which allocate all of their distributable profits for each financial year.
I. – The investment property companies referred to in I de l’article 33 de la loi n° 63-254 du 15 mars 1963 sont exonérées de l’impôt sur les sociétés pour la fraction de leur bénéfice qui provient de la location de leurs immeubles. II. – When, under the conditions set out in I of Article 11 of the 1985 Finance Act no. 84-1208 of 29 December 1984, they hold shares…
I. – Listed property investment companies are defined as joint stock companies listed on a regulated market in accordance with Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC, whose share capital is not less than EUR 15…
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75001, Paris France
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is a Registered Trademark of
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182, rue de Rivoli
75001, Paris France
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