Exit Tax On Eligible Assets That Become Subject To The French Reit-Like Regime

Companies that have elected for the specific REIT-like tax regime set forth under Articles 208 C et seq of the French tax code (Société d'Investissements Immobiliers Cotée, SIIC) are exempt from corporate income tax on (i) rental income (realized either directly or through tax flow-through partnerships), (ii) capital gains arising from the sale of eligible real estate assets, and (iii) dividends received from subsidiaries having themselves elected for the specific SIIC tax regime. Article 208 C of the French tax code, however, provides that the election for the SIIC tax regime gives rise to the taxation of the unrealized latent capital...

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