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Article 223 F of the French General Tax Code

The fraction of the capital gain or loss relating to the transfer between group companies of a fixed asset, acquired since the date on which it was entered on the balance sheet of the group company which made the first transfer, is not taken into account for the calculation of the profit or loss or of the overall net long-term capital gain or loss in respect of the financial year…

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Article 223 G of the French General Tax Code

1. Where the parent company opts for the regime provided for in paragraph I of Article 220 quinquies: a) The overall deficit declared in respect of a financial year shall be set off against the overall profit or, where applicable, against the profit that the parent company declared in respect of the financial year preceding application of the regime defined in this section, under the conditions provided for in Article…

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Article 223 H of the French General Tax Code

I.-1. The parent company of the group shall subject to separate taxation at the rate provided for in the second paragraph of a of I of Article 219 the overall net income from the sale, concession or sub-concession of assets held or taken under concession by a member company of the group for which the option for the taxation regime provided for in Article 238 est exercée. This option is…

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Article 223 I of the French General Tax Code

1. a) Losses incurred by a group company in respect of financial years prior to its entry into the group may only be offset against its profits, subject to the limits and conditions set out in the third paragraph of I of Article 209 ; b) The share of losses corresponding to the additional depreciation resulting from the revaluation of its fixed assets by a company in the group, is…

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Article 223 K of the French General Tax Code

If a subsidiary company leaves the group, the deficit declared by it in respect of a financial year subsequent to its leaving the group does not constitute, for the application of the provisions of article 220 quinquies, an expense deductible from previous profits taken into account to determine overall profit.

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Article 223 L of the French General Tax Code

1. (not applicable). 2. Group companies may not benefit from the tax credit mentioned in articles 220 quater and 220 quater A. 3. Deductions made by group companies under the provisions of II of article 217 undecies in respect of sums paid to subscribe for the capital of other companies in the same group are reintegrated into the overall result. 4. (Repealed) 5. For the calculation of profit-sharing and the…

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Article 223 N of the French General Tax Code

1. Each company in the group is required to pay the advance payments provided for in Article 1668 for the twelve-month period starting from the beginning of the financial year in respect of which this company joins the group. If the parent company’s assessment of the tax due in respect of the taxable income for that period shows that the advance payments made exceed the tax due, the excess is…

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Article 223 O of the French General Tax Code

1. The parent company is substituted for the companies in the group for the purposes of setting off against the amount of corporation tax for which it is liable in respect of each financial year: a. Tax credits attached to income received by a group company and which did not give entitlement to the application of the parent company regime referred to in Articles 145 and 216 ; b. Tax…

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Article 223 Q of the French General Tax Code

The parent company shall file the declaration of overall income for each financial year under the conditions provided for in Article 223. It attaches a statement of grants and debt write-offs not used to determine the overall result for financial years opened before 1 January 2019 and a statement of the adjustments provided for in Article 223 F, as well as those provided for in the second, third and sixth…

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Article 223 R of the French General Tax Code

In the event that one of the companies mentioned in the fifth paragraph of Article 223 B in the wording in force for financial years commencing before 1 January 2019, indirect subsidies that arise from a transfer of assets making up the fixed assets or portfolio securities excluded from the long-term capital gains or capital losses regime in accordance with Article 219 for a price different from their actual value,…

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