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Article 143 quater of the French General Tax Code

Distributions of profits made by companies that have entered into an agreement with the Minister of the Economy and Finance in accordance with the provisions of l’ordonnance n° 59-248 du 4 février 1959, are exempt from the withholding tax provided for in 2 of Article 119 bis insofar as the profits distributed come from the activities of the company referred to in the agreement and do not exceed 5% of…

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Article 145 of the French General Tax Code

1. The parent company tax regime, as defined in Article 216, is applicable to companies and other bodies subject to corporation tax at the standard rate which hold equity interests satisfying the following conditions: a. The equity securities must be in registered form or be deposited or registered in an account held by one of the following intermediaries: – intermediaries authorised to carry out custody account-keeping activities for financial instruments…

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Article 146 quater of the French General Tax Code

The withholding tax provided for in 1 of l’article 119 bis et du prélèvement prévu au I de article 125 A interest, arrears and any other income from loans contracted before 1 January 1965 for the development of priority urbanisation areas, by local authorities and by bodies holding concessions for this development.

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Article 148 of the French General Tax Code

Dividends, interest, arrears and all other income from foreign securities which French insurance and reinsurance companies are obliged to deposit and keep on deposit abroad, in order to constitute sureties, are exempt from the proportional tax on income from foreign securities which are not subject to the subscription system, mathematical reserves and any other reserves for claims to be settled and for current risks, when this obligation is imposed on…

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Article 150 ter of the French General Tax Code

1. Subject to the provisions specific to industrial and commercial profits, non-commercial profits and agricultural profits, net profits realised, directly, through an intermediary or via a trust, on the settlement or disposal for consideration of financial contracts, also referred to as “financial futures instruments”, mentioned in III of l’article L. 211-1 of the Monetary and Financial Code, by individuals domiciled in France for tax purposes within the meaning of Article…

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Article 150 duodecies of the French General Tax Code

In the event of a gift of securities as provided for in I of article 978 , the net gain corresponding to the difference between the value of the securities used to determine the tax advantage provided for in that same I and their acquisition value is subject to income tax, at the time of the gift, according to the rules provided for in articles 150-0 A et seq.

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Article 150-0 A of the French General Tax Code

I. – 1. Subject to the provisions specific to industrial and commercial profits, non-commercial profits and agricultural profits and to Articles 150 UB and 150 UC, net gains from disposals for consideration, made directly, through an intermediary or via a trust, of transferable securities, corporate rights, securities mentioned in 1° of article 118 and to 6° and 7° of l’article 120, rights relating to these values, rights or securities or…

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Article 150-0 B of the French General Tax Code

Subject to the provisions of article 150-0 B ter, the provisions of article 150-0 A do not apply, in respect of the year in which the securities are exchanged, to capital gains and losses realised in connection with a public offer, merger, demerger, takeover of a mutual fund by an open-ended investment company, conversion, division, or consolidation, carried out in accordance with the regulations in force or a contribution of…

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Article 150-0 B bis of the French General Tax Code

The gain derived from the contribution, before it is payable in cash, of the claim referred to in the second paragraph of 2 of I of article 150-0 A is deferred, at the express option of the taxpayer, at the time of the transfer, redemption, repayment or cancellation of the securities received as consideration for this contribution or, upon the transfer by the taxpayer of his tax domicile outside France…

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Article 150-0 B ter of the French General Tax Code

I. – Taxation of the capital gain realised, directly or through an intermediary, in connection with a contribution of transferable securities, corporate rights, securities or rights relating thereto as defined in article 150-0 A to a company subject to corporation tax or an equivalent tax is deferred if the conditions set out in III of this article are met. The taxpayer mentions the amount of the capital gain in the…

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