Article 990 J of the French General Tax Code
I. – Natural persons constituting or benefiting from a trust defined in Article 792-0 bis are subject to a levy set at the highest rate mentioned in 1 of Article 977. II. – Where their administrator is subject to the law of a State or territory that has concluded an administrative assistance agreement with France with a view to combating tax fraud and tax evasion, the levy does not apply…