The tax administration issued Guideline 13 D-1-06 of 10 February 2006 regarding the approval given by the tax authorities on allocation of securities to shareholders within the framework of a transfer of complete branches of activities under the favourable regime. The Guideline complements the provisions of Guideline 13 D-1-03 of 2 June 2003. Details of the new Guideline are summarized below.
(a) Background. Under Art. 115 (2) of the French Tax Code (Code Gé…