Wishes 2017

2 JANUARY 2017 

Our team presents its best wishes for the new year   

The 3% tax – legal ownership vs. economic ownership

27 DECEMBER 2016

The 3% tax: Legal ownership vs. economic ownership... 

A company that reveals the identity of the beneficiary of shares will meet its reporting obligation!

Allocations of land and buildings: a risky issue

21 DECEMBER 2016

Allocations of land & buildings: a risky issue

As the year end approaches, now is a good moment to reconsider the above question, which was the subject of two important rulings in 2016 (Conseil d’Etat rulings nos. 367467 SARL Daves and 380400 LG Services of 15 February 2016) followed by a recent report issued by AFREXIM (the French Association of Property Valuation Firms).  

Imputation of land losses: .....

25 NOVEMBER 2016

Charging of losses on land: the prerogative of the usufructuary or of the bare owner?  

In 2016, we have seen a number of decisions concerning the use of dividing up the ownership – which under French law consists of splitting full ownership of an asset into 2 distinct rights: usufruct and bare ownership – of shares in an SCI (société civile immobilière, real estate partnership).  

Contribution of temporary usufruct of shares in an SCI...

25 NOVEMBER 2016

Contribution of temporary usufruct of shares in an SCI subject to Income Tax (IT) to a company subject to Corporate Income Tax (CIT): an abuse of law?  

Among the clarifications made in 2016 concerning the dividing-up of shares of SCI, the Committee of Abuse of Tax Law decided by a Notice of 13 June 2016, on the abusive or not abusive nature of a contribution of the temporary usufruct of the shares of an SCI (IT) to a company subject to CIT.