Article 121 of the French General Tax Code
1. For the application of Article 120, the incorporation of reserves by a foreign company into its share capital does not constitute a chargeable event for income tax. The provisions set out in 1 of Article 115 are applicable in the event of a merger or demerger involving companies at least one of which is foreign. The provisions set out in 2 of article 115 are applicable in the event…