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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…

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Article 122 of the French General Tax Code

1. Subject to 2, the income is determined by the gross value in euros of the products collected according to the exchange rate on the day of the payments, without any deduction other than that of the taxes established in the country of origin and the payment of which is the responsibility of the beneficiary. The amount of the lots is fixed by the actual amount of the lot in…

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Article 123 of the French General Tax Code

With regard to funding securities issued by foreign States, the taxable event is deferred to the time of the first negotiation of these securities. In this case, the taxable income is determined by the negotiation price.

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Article 123 bis of the French General Tax Code

1. When an individual domiciled in France holds directly or indirectly at least 10% of the shares, units, financial rights or voting rights in a legal entity-a legal person, body, trust or comparable institution-established or incorporated outside France and subject to a privileged tax regime, the profits or positive income of this legal entity are deemed to constitute income from movable capital of this individual in the proportion of the…

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Article 124 of the French General Tax Code

Sont considérés comme revenus au sens du présent article, lorsqu’ils ne figurent pas dans les recettes provenant de l’exercice d’une profession industrielle, commerciale, artisanale ou agricole, ou d’une exploitation minière, les intérêts, arrérages, primes de remboursement et tous autres produits : 1° Des créances hypothécaires, privilégiées et chirographaires, à l’exclusion de celles représentées par des obligations, effets publics et autres titres d’emprunts négociables entrant dans les prévisions des articles 118…

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Article 124 B of the French General Tax Code

The taxation regime for gains derived by natural persons from disposals made directly or through intermediaries, of debt securities negotiable on a regulated market pursuant to a specific legislative provision and not likely to be listed, follows that of the proceeds of such securities. The provisions of the first paragraph apply to disposals of units in debt mutual funds whose term on issue is less than or equal to five…

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Article 124 C of the French General Tax Code

The amount of the gains mentioned in Article 124 B is set in accordance with the conditions set out in the first paragraph of 1 and 2 of Article 150-0 D. However, the costs of acquisition for valuable consideration may not be determined on a flat-rate basis. For the determination of net gains from the sale of bonds or contracts mentioned in I of article 125-0 A, the acquisition price…

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Article 124 D of the French General Tax Code

The debt securities referred to in the first paragraph of article 124 B must be registered in an account or nominative deposit with the persons referred to in article 242 ter for the assessment of income tax. The persons mentioned in article 242 ter must then provide the administration with all the information required to establish the tax, and taxpayers must also provide them with the amount of the disposals…

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