Article 238 bis K of the French General Tax Code
I. – Where rights in a company or group referred to in Articles 8,8 quinquies, 239 quater, 239 quater B, 239 quater C or 239 quater D are included in the assets of a legal entity liable to corporation tax under the conditions of ordinary law or an industrial, commercial, craft or agricultural business subject to income tax by operation of law under a system of actual profit, the share…