A new French tax regime for listed real estate …（一个新的法国上市的房地产税收体制u2026）.pdfVIP

A new French tax regime for listed real estate investment company, SIIC A new tax regime for real estate investment companies has been introduced in France by the Finance Act for 2003. The tax regime applies to listed French real estate investment companies, sociétés d’investissements immobiliers cotées (‘SIIC’) and has been introduced in order to make the French real estate companies more competitive with the existing regimes in Europe such as the Belgian real 1 estate companies with fixed capital (closed-end fund) (‘Sicafi’) , the Dutch fiscal investment institution (‘FBI’)2 3 and the German management company with a real estate open-end fund (‘KAG’) and the US equivalent i.e. the real estate investment trusts (‘REIT’). No major changes are expected during the end of the parliamentary process before the finance bill is enacted by year-end. The double faced status of SIIC The SIIC will be exempt from corporation tax on qualifying income, defined as real estate rental income and capital gains on the sale of the real estate with which the rental income was generated. It can nevertheless undertake other activities as speculative real estate development and intra-group loans, provided that its core business rests the rental of real estate to third parties. The non-qualifying income will be taxed at the normal corporate tax rate. This tax exemption on qualifying income is conditioned upon a compulsory distribution of at least 85% of the rental income and at least 50% of the capital gain within two years of the disposal of the real estate, which both will be taxed as dividends with no avoir fiscal at the shareholders level. The SIIC therefore benefits from a qu