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Enacted in 2005, Article 210-E of the French General Tax Code defines a reduced rate tax regime for capital gains stemming from sales or transfers of real-estate properties. The beneficiaries are the sellers selling or transferring their assets to SIIC, SCPI, OPCI and also subsidiaries of SIIC or SPPICAV. In return, the buyer must, among other obligations, undertake to hold the assets for a minimum of 5 years. The phenomenal success of this regime resided in the very attractive taxation rates, 16.5% (then 19%) instead of 34.43% on capital gains.
This regime came to an end on 31 December 2011. Time is therefore of the essence. What effects has Article 210-E had on the investment market? Who has benefited the most? What type or size of assets was targeted?
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19 July 2012