Last week, we had the pleasure of hosting a conference dedicated to the share contribution–sale mechanism (apport-cession – Article 150-0 B ter of the French Tax Code).
Behind its apparent simplicity, this regime hides a number of technical pitfalls and subtleties, including:
➡️ The sequencing of transactions
➡️ The holding period requirements (particularly when shares derive from management packages)
➡️ The notion of control
➡️ The eligibility of reinvestments
➡️ Threshold calculations, filings constraints, and reporting obligations
Michel Dayanithi and Margaux Niclout from Syntaxe provided an in-depth analysis of these issues, drawing on recent case law and practical insights from their advisory work.
Jonathan Rosen and Gaëtan de Marne from Etsa Patrimoine presented a case study focused on reinvestment strategies, offering a complementary perspective.
The combined insights of all speakers provided a comprehensive view of the share contribution-sale mechanism, in both its tax and economic dimensions.
A warm thank-you to all participants and speakers for their engagement and the quality of the discussions.
