Doing Business in France - RSM International

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4.6.2 Net wealth tax 4.6.2.1 Taxable persons French residents are subject to net wealth tax (impôt de solidarité sur la fortune, ISF) on their worldwide assets. However, as from 1 January 2009, taxpayers who become French tax residents, but who have been non-resident on a continuous basis over the preceding 5 years, are subject to net wealth tax during the initial 5-year period only on their assets located in France. Non-residents are taxable only on their assets located in France. 4.6.2.2 Taxable base Net wealth tax applies to all assets (including movables, securities, cash, real property) which are not specifically exempt if their overall net value (i.e. after deduction of qualifying liabilities) exceeds a certain threshold, which is revised annually and which is currently EUR 790,000. All items must be assessed at their market value on 1 January of the relevant year. The value of the taxpayer’s main residence may be discounted by 30%. The tax is assessed and paid spontaneously by the taxpayer when filing his wealth tax return. The following assets are exempt in whole or in part from the tax: • business assets • antiques, works of art and collector’s items • literary and artistic property rights • financial investments by non-residents (subject to certain limitations), other than in real property companies • woods and forests (for three quarters of their value) • agricultural properties on long-term lease (which enjoy a full or partial exemption, subject to certain conditions) and • retirement pensions and annuities (subject to certain conditions) Debts other than those relating to exempt assets may be deducted when assessing the tax base. 44 | DOING BUSINESS IN FRANCE
4.6.2.3 Calculation Net wealth tax is assessed on the following cumulative progressive scale schedule: Taxable amount (EUR) Rate (%) up to 790,000 0 790,000 – 1,290,000 0.55 1,290,000 – 2,530,000 0.75 2,530,000 – 3,980,000 1.00 3,980,000 – 7,600,000 1.30 7,600,000 – 16,540,000 1.65 over 16,540,000 1.80 There is a maximum amount or burden for the wealth tax: it cannot exceed, combined with the income tax paid the same year, 50% of the family unit incomes. The wealth tax is reduced accordingly if this limit is exceeded. This limitation only applies to French tax residents. 4.6.3 Inheritance and gift tax 4.6.3.1 Inheritance tax In case of death, the heirs and legatees must file a detailed declaration exhaustively listing and valuing the assets which are bequeathed to them, within 6 months from the date of death (12 months in the event the deceased resided outside France at the time of death). Where the deceased was resident in France, all assets, including property, whether movable or immovable, owned by the deceased at the time of death are taxable in France (unless applicable tax treaties provide otherwise) and should be declared. Where the deceased was non-resident, French inheritance tax is due in respect of assets (movables and immovables) located in France. This would include French-situs property and shares issued by French-registered companies. Subject to treaty provisions, the assets, wherever located, are taxable in France from 1 January 1999, where the beneficiary has been fiscally resident in France for at least 6 years during the 10-year period preceding that in which the inheritance occurs. DOING BUSINESS IN FRANCE | 45
Page 1 and 2: Doing Business in France
Page 3 and 4: Foreword RSM International RSM Inte
Page 5 and 6: Contents 1 General Information 4 Ge
Page 7 and 8: Lake Cap-de-Long in Hautes, Pyrenee
Page 9 and 10: The legislative branch is composed
Page 11 and 12: 2 Types of business organisations 2
Page 13 and 14: 2.2.1.2 Private Limited Company und
Page 15 and 16: 2.2.2.3 Simplified Join Stock Compa
Page 17 and 18: 2.3 Dissolution and liquidation of
Page 19 and 20: 3 Employment Labor relations are go
Page 21 and 22: 3.4 Termination of the employment c
Page 23 and 24: 3.6 The social security system Fran
Page 25 and 26: 3.7.3 Employee treatment in France
Page 27 and 28: Group treatment Incentives Anti-avo
Page 29 and 30: 4.2.3 General Expenses General expe
Page 31 and 32: 4.2.5 Controlled Foreign Company (C
Page 33 and 34: 4.2.7.1.2 Withholding tax on intere
Page 35 and 36: Croatia 0 0 0 15 0 0 0 Cyprus 0 3 0
Page 37 and 38: Switzerland resident control13 non-
Page 39 and 40: Secondly, if the amount of interest
Page 41 and 42: 4.2.10.2 World tax consolidation Re
Page 43 and 44: 4.4.2 Research and development (R&D
Page 45 and 46: La Défense - the main business dis
Page 47: 4.6.1.2 Establishment of overall in
Page 51 and 52: 4.7.2.2 Apprenticeship tax (taxe d
Page 53 and 54: 5 Accounting regulations & standard
Page 55 and 56: St. Stephen’s Cathedral, Vienna S
Page 57 and 58: 5.8 Adoption of IFRS in France The
Page 59 and 60: Lyon/South East France RSM CCI Cons
Page 61 and 62: Notes
Page 63 and 64: Palais de la Bourse, Bordeaux DOING

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