On 29 May 2019, the French tax authorities published Ruling No. BOI-RES-000040-20190529, which clarifies the holding condition for the special regime for mergers. Prior to 1 January 2018, the beneficiary company receiving shares must commit to holding the shares for at least three years following the transfer to be eligible for the special regime. From 1 January 2018, the three-year condition was abolished where the transfer of shares is considered as a transfer of a full branch of activity.…