Conference: Share Contribution: Securing the Deferral and Structuring the Aftermath

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.

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