Article 990 E of the French General Tax Code
The tax provided for in article 990 D is not applicable: 1° To international organisations, sovereign States, their political and territorial subdivisions, and to legal persons, bodies, trusts or comparable institutions that they majority control; 2° To legal entities: legal persons, bodies, trusts or comparable institutions, a) Whose real estate assets, within the meaning of Article 990 D, located in France, represent less than 50% of the French assets held…