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We would like to remind you that the annual filing deadline for the 3% tax is May 15, 2024.

For the record, article 990 D of the French General Tax Code (” CGI “) subjects all legal entities holding real estate in France to a 3% tax on the market value of such real estate, subject to the application of various exemptions.

Article 990 E of the CGI provides for exemption from this tax on the basis of an annual declaration including the value and consistency of the assets held on January1 of the year. In practice, this exemption means that all entities interposed between the property and its ultimate beneficiary must file a declaration (form n°2746) with the relevant tax department before May 15 of each year.

As a result, some of your group’s entities may be concerned by this reporting obligation in respect of their direct or indirect ownership of assets in France. If so, they will need to complete a declaration no. 2746 and file it with the tax authorities before May 15 in order to benefit from the 3% tax exemption.

We would also draw your attention to the fact that this declaration must now be filed electronically via the professional space of the entity concerned.

The tax team is at your disposal to help you prepare this form for 2024.

Eglantine Lioret and Valérie Farez, partners

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