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Article 239 quater of the French General Tax Code

I. – Economic interest groupings formed and operating under the conditions provided for in articles L. 251-1 to L. 251-23 of the French Commercial Code do not fall within the scope of 1 of article 206, but each of their members is personally liable, for the share of profits corresponding to his rights in the grouping, either to income tax, or to corporation tax if they are legal entities subject…

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Article 239 quater A of the French General Tax Code

Les sociétés civiles de moyens définies à Article 36 of law no. 66-879 of 29 November 1966 does not fall within the scope of corporate income tax, even when these companies have adopted the status of cooperative; each of their members is personally liable, for the share of profits corresponding to his rights in the company, either to income tax or to corporate income tax if the company is subject…

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Article 239 quater B of the French General Tax Code

Public interest groupings formed and operating under the conditions provided for in Chapter II of the loi n° 2011-525 du 17 mai 2011 de simplification et d’amélioration de la qualité du droit do not fall within the scope of 1 of article 206, but each of their members is personally liable, for the share of the surpluses corresponding to its rights in the grouping, either to income tax or to…

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Article 239 quater C of the French General Tax Code

European economic interest groupings that are set up and operate under the conditions provided for by Council of the European Communities regulation no. 2137-85 of 25 July 1985 do not fall within the scope of 1 of Article 206. Each of their members is personally liable, for the share of the results corresponding to his rights in the grouping, either to income tax or to corporation tax if it is…

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Article 239 quater D of the French General Tax Code

The healthcare cooperation groupings mentioned in articles L. 6133-1 and L. 6133-4 of the Public Health Code and the social and medico-social cooperation groupings mentioned in Article L. 312-7 of the Social Action and Family Code do not fall within the scope of 1 of article 206, but each of their members is personally liable, for the share of the surpluses corresponding to his rights in the grouping, either to…

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Article 239 quinquies of the French General Tax Code

I. – Notwithstanding the provisions of 1 of Article 206, the following are not liable for corporation tax: 1° Mixed forest management syndicates defined in articles L. 232-1 et L. 232-2 du code forestier; 2° Les groupements syndicaux forestiers prévus aux articles L. 233-1 and L. 233-2 of the same code. II. – In accordance with the provisions of article 218 bis, legal entities which are members of such a…

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Article 239 sexies of the French General Tax Code

I. – When the purchase price paid by the lessee for the property leased under a finance lease entered into with a société immobilière pour le commerce et l’industrie is less than the difference between the value of the property when the agreement was signed and the total amount of depreciation that the lessee would have been able to apply if it had owned the property since that date, the…

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Article 239 sexies B of the French General Tax Code

The provisions of the first paragraph of I and those of paragraph II of Article 239 sexies are applicable to lessees who acquire buildings leased to them by companies or bodies other than real estate companies for commerce and industry. A decree sets out the terms and conditions for applying the provisions of this article and the reporting obligations. (Cf. Instruction 1996-10-23 4H-4-96.)

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Article 239 sexies C of the French General Tax Code

PROVISIONS APPLICABLE TO CONTRACTS CONCLUDED BEFORE 31 December 1995. The cost price of the asset acquired at the end of a leasing contract is increased by the sums reintegrated pursuant to articles 239 sexies and 239 sexies B. The fraction of the price which exceeds, where applicable, the purchase price of the land, by the lessor, considered as the cost price of the buildings, is depreciated under the conditions mentioned…

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Article 239 sexies D of the French General Tax Code

By way of derogation from the provisions of I of Article 239 sexies and those of l’article 239 sexies B, tenants meeting the conditions of a and b of article 39 quinquies D are exempt from any reintegration on the occasion of the disposal of industrial and commercial property leased under a finance lease with an effective term of at least fifteen years. These provisions apply to transactions entered into…

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