Article 828 bis of the French General Tax Code
1. The following are exempt from registration duties, land registration tax and the contribution provided for in Article 879 transfers of property, rights and obligations resulting from the transformation : a) of non-trading property investment companies into undertakings for collective property investment; b) of non-trading companies with a strictly real estate object, the units of which are held by an insurance company in representation of mathematical provisions relating to commitments…