When the settlor of a trust defined in Article 2011 of the Civil Code does not carry on an activity falling within the articles 34 or 35, an agricultural activity within the meaning of article 63, a professional activity within the meaning of 1 of l’article 92 or a civil activity subject to corporation tax, the transfer of assets or rights into a fiduciary estate is not a chargeable event…
Where the settlor’s rights representing the property or rights transferred into the trust assets are not recorded in the balance sheet of a company, the trust income is taxed in the name of each settlor for the share of income corresponding to his rights representing the property or rights transferred into the trust assets, in proportion to the market value of the property or rights placed in trust, assessed on…
I. – In the event of a transfer for valuable consideration of all or part of the settlor’s rights representing the assets or rights transferred into the trust assets which are not entered on the balance sheet of a company, the results of the trust assets are determined, on the date of the transfer, in accordance with the conditions set out in articles 201 et seq and taxed in the…
Where the settlor does not carry on an activity covered by Articles 34 or 35, an agricultural activity within the meaning of article 63, a professional activity within the meaning of 1 of article 92 or a civil activity subject to corporation tax, and by way of exception to the provisions of II of article 238 quater P, the transfer of assets or rights from the trust estate to the…
I. – Where a person acquires the right to payment of the principal or the right to payment of interest on a bond arising from a stripping carried out before 1 June 1991, the redemption premium means the difference between: a) The principal or interest that he receives; b) The subscription price or the original acquisition price of the corresponding right. II. – Constitutes a redemption premium: 1. For the…
I. – When the redemption premium provided for at the time of issue or at the time of the original acquisition of the right exceeds 10% of the nominal value or acquisition price of that right, or when the contract for the issue of a bond provides for partial or total capitalisation of interest, the premium or interest is taxed after distribution by annual instalments. Each annual instalment is taxed…
A Conseil d’Etat decree specifies the terms of application of articles 238 septies A and 238 septies B and their impact on the calculation of any capital gains or losses realised in the event of disposal, as well as the obligations incumbent on issuers and intermediaries. (1) Annex II, art. 39 EA and 50 A.
The articles 238 septies A, 238 septies B, 238 septies C and 238 septies E apply to units in debt securitisation funds where their term on issue is more than five years.
I. – Constitutes a redemption premium: 1. For the negotiable loans referred to in article 118 and 6° and 7° of Article 120, the negotiable debt securities referred to in article 124 B and all other negotiable or non-negotiable debt or capitalisation securities or contracts, issued or entered into on or after 1 January 1993, the difference between the sums or values receivable, whatever their nature, with the exception of…
In the event of the transfer of securities mentioned in article 118, at 6° and 7° of article 120 and to Article 1678 bis as well as treasury bills on formulas and entered on the balance sheet of a company at the close of the first financial year opened as from 1 January 1993, the result of the disposal is for tax purposes calculated in relation to their acquisition cost,…
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is a Registered Trademark of
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182, rue de Rivoli
75001, Paris France
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is a Registered Trademark of
PETROFF LAW FIRM (SELARL LEGASTRAT)
182, rue de Rivoli
75001, Paris France
RCS Paris n°814433470
Paris Bar Registration n° (Toque) C2396
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