Part One: State taxes

I. – Companies at least 75% of whose turnover is derived from the operation of ships used for commercial purposes may, by option, be subject to the regime defined in this article for the determination of taxable profits derived from the operation of these ships. The option referred to in the first paragraph is valid provided that the company operates under the flag of a Member State of the European…

I. – 1. Where a legal entity established in France and liable for corporation tax operates a business outside France or holds directly or indirectly more than 50% of the shares, stocks, financial rights or voting rights in a legal entity: legal person, body, trust or comparable institution, established or incorporated outside France and where this business or legal entity is subject to a privileged tax regime within the meaning…

1. Capital gains subject to tax at the reduced rate provided for in a of I of article 219, reduced by the amount of this tax, are transferred to a special reserve. The entry to this special reserve ceases for capital gains taxed in respect of financial years commencing on or after 1 January 2004. 2. Amounts withdrawn from this reserve are credited to income for the financial year in…

Profits placed under the exemption regime subject to reinvestment provided for in article 238 octies are attached to the results of the current financial year when they are distributed. They are retained: For half of their amount, when this distribution occurs more than four years but less than seven years after their realisation; For 30% of their amount, when this distribution occurs at least seven years after their realisation. A…

The provisions of this article apply to capital gains, other than those referred to in the second paragraph of II of article 238 octies, realised before the entry into force, under conditions set by decree in the Conseil d’Etat, of articles 39 duodecies to 39 quindecies A. 1. Capital gains, other than those realised on goods, resulting from the free allocation of shares or corporate units (capital shares), following mergers…

I. – The provisions set out in 7a of Article 38, in Ib and in V of article 93 quater, to articles 112,115,120,121,151 octies, 151 octies A, 151 octies B, 151 nonies, 208 C, 208 C bis, 210 A to 210 C, 210 F, the second and third paragraphs of II of l’article 220 quinquies and articles 223 A to 223 U, are applicable: 1° With regard to mergers, to…

1. Net capital gains and profits generated on all assets contributed as a result of a merger are not subject to corporation tax. The same applies to any capital gains generated by the acquiring company on the cancellation of shares or units in its own capital that it receives or that correspond to its rights in the acquired company. The entry in the assets of the acquiring company of the…

1. Article 210 A applies to the partial contribution of assets of one or more complete branches of business or similar items. The same Article 210 A applies to the demerger of a company comprising at least two complete branches of activity where each of the recipient companies receives one or more of these branches. Contributions of shareholdings relating to more than 50% of the capital of the company whose…

1. The provisions of articles 210 A and 210 B apply to transactions exclusively involving legal entities or bodies liable for corporation tax. 2. These provisions only apply to mergers, demergers and partial contributions of assets of a complete branch of activity carried out for the benefit of foreign legal entities by French legal entities if the elements contributed are effectively attached to a permanent establishment of the foreign legal…

The capital gains that may arise from a transaction referred to in article 48 of law n° 78-763 of 19 July 1978 on the status of sociétés coopératives de production are taxable in the name of the société coopérative de production under the following conditions: a. Capital gains relating to non-depreciable fixed assets are subject to a deferral of taxation until the disposal, for consideration, of these fixed assets by…