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Article 164 A of the French General Tax Code

The French source income of persons who do not have their tax domicile in France is determined according to the rules applicable to income of the same nature received by persons who have their tax domicile in France. However, none of the expenses deductible from overall income pursuant to the provisions of this code may be deducted.

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Article 164 B of the French General Tax Code

I. The following are considered as French source income: a. Income from real estate located in France or rights relating to such real estate; b. Income from French transferable securities and all other transferable capital invested in France; c. Income from businesses located in France; d. Income from professional activities, whether salaried or not, carried out in France or profit-making operations within the meaning of the article 92 and carried…

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Article 164 D of the French General Tax Code

Natural persons carrying on business in France or owning property there, without having their tax domicile there, as well as the persons mentioned in 2 of the article 4 B, may be invited by the tax department to designate, within ninety days of receipt of this request, a representative in France authorised to receive communications relating to the assessment, collection and litigation of the tax. However, the obligation to appoint…

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Article 167 of the French General Tax Code

1. A taxpayer domiciled in France who transfers his residence abroad is liable to income tax on the income he has disposed of during the year of his departure up to the date of his departure, on the industrial and commercial profits he has made since the end of the last taxed financial year, and on any income he has acquired without having disposed of it prior to his departure….

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Article 167 bis of the French General Tax Code

I. – 1. Taxpayers who have been domiciled in France for tax purposes for at least six of the ten years preceding the transfer of their tax residence outside France are taxable on the transfer in respect of unrealised capital gains on the corporate rights, securities or rights referred to in 1 of I of Article 150-0 A held, directly or indirectly, by the members of their tax household on…

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Article 168 of the French General Tax Code

1. In the event of a marked disproportion between a taxpayer’s lifestyle and his or her income, the income tax base is increased to a lump sum determined by applying the following scale to certain elements of this lifestyle, when this sum is greater than or equal to €50,447; this limit is increased each year in the same proportion as the upper limit of the first bracket of the income…

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