Article 151 quater of the French General Tax Code
Where the construction lease provided for by the articles L. 251-1 to L. 251-8 of the Code de la construction et de l’habitation is accompanied by a clause providing for the transfer of ownership of the land to the lessee in return for payment of a rent supplement, the capital gain generated on the sale of the land is taxed under the conditions set out in articles 35,150 U, 244…