Section II: Taxable income

When a legal entity subject to corporation tax ceases to be subject to it, its profits and reserves, whether capitalised or not, are deemed to be distributed to the partners in proportion to their rights. This provision is applicable, where applicable, in proportion to the profits that cease to be subject to this tax. The provisions of this article do not apply to companies eligible for the regime provided for…

The conversion of a company that is not exempt from corporation tax into an open-ended investment company has the same tax consequences as the distribution of its liquidation surplus.

Distributed income shall not include: 1° Allocations which, for members or shareholders, have the character of repayments of contributions or share premiums. However, a distribution shall only be deemed to be of this nature if all profits and reserves other than the legal reserve have previously been distributed. Subject to the provisions of 3°, the following shall not be considered as contributions for the application of this provision: a. Reserves…

For the application of articles 109 and 112, the direct incorporation of profits into the capital is treated as an incorporation of reserves.

1. In the event of a merger or demerger of companies, the allocation of securities, sums or values to the members of the transferring company in consideration for the cancellation of the securities of that company shall not be considered as a distribution of income from movable property. These provisions apply to mergers or demergers of open-ended investment companies with a preponderance of real estate capital referred to in 3°…

I. The sums not distributed by an open-ended investment company on the date of its absorption, carried out in accordance with the regulations in force, by a mutual fund are taxed when they are distributed among the unit-holders of the mutual fund. These provisions are applicable in the event of the demerger of an open-ended investment company in accordance with the regulations in force. II.-In the event of the absorption,…

Where a company having its registered office in France and liable to the tax provided for in Chapter II of this Title carries on business in Saint-Pierre-et-Miquelon, Mayotte, New Caledonia, French Polynesia, the Wallis and Futuna Islands and the French Southern and Antarctic Territories where taxation is applied to distributions of profits, the double taxation to which distributions of profits made by this company may be subject as a result…

1. Profits made in France by foreign companies shall be deemed to be distributed, in respect of each financial year, to shareholders who do not have their tax domicile or registered office in France. The profits referred to in the first paragraph shall mean the total amount of profits, whether taxable or exempt, after deduction of corporation tax. 1. bis (Provisions not applicable). 2. However, the company may request that…