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Article 120 of the French General Tax Code

Sont considérés comme revenus au sens du présent article : 1° Dividends, interest, arrears and all other income from shares of any kind and founders’ shares in financial, industrial, commercial, civil and generally any other companies, corporations or enterprises whose registered office is situated abroad regardless of when they were created; 2° Interest, income and profits from interest shares and limited partnerships in companies, corporations and enterprises whose registered office…

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Article 121 of the French General Tax Code

1. For the application of Article 120, the incorporation of reserves by a foreign company into its share capital does not constitute a chargeable event for income tax. The provisions set out in 1 of Article 115 are applicable in the event of a merger or demerger involving companies at least one of which is foreign. The provisions set out in 2 of article 115 are applicable in the event…

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Article 122 of the French General Tax Code

1. Subject to 2, the income is determined by the gross value in euros of the products collected according to the exchange rate on the day of the payments, without any deduction other than that of the taxes established in the country of origin and the payment of which is the responsibility of the beneficiary. The amount of the lots is fixed by the actual amount of the lot in…

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Article 123 of the French General Tax Code

With regard to funding securities issued by foreign States, the taxable event is deferred to the time of the first negotiation of these securities. In this case, the taxable income is determined by the negotiation price.

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Article 123 bis of the French General Tax Code

1. When an individual domiciled in France holds directly or indirectly at least 10% of the shares, units, financial rights or voting rights in a legal entity-a legal person, body, trust or comparable institution-established or incorporated outside France and subject to a privileged tax regime, the profits or positive income of this legal entity are deemed to constitute income from movable capital of this individual in the proportion of the…

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