3: Income from securities issued outside France and similar income

Articles in this section · 5

Article 122

French General Tax CodeIn force

Updated 8 Nov 2023

1. Subject to 2, the income is determined by the gross value in euros of the products collected according to the exchange rate on the day of the payments, without any deduction other than that of the taxes established in the country of origin and the payment of which is the responsibility of the beneficiary.

The amount of the lots is fixed by the actual amount of the lot in euros.

For redemption premiums, the income is determined by the difference between the sum redeemed and the issue rate of the loans under the conditions referred to in 3° of article 119.

2. The income from capitalisation bonds or contracts as well as investments of the same nature mentioned in 6° of article 120 is made up of the difference between, on the one hand, the gross sums repaid to the beneficiary and, on the other hand, the amount of premiums paid, where applicable, since the acquisition of this bond or contract, increased, in this case, by the acquisition price of the bond or contract.

Where these proceeds are attached to bonds or contracts taken out with insurance companies established outside France in a Member State of the European Union, or in another State party to the Agreement on the European Economic Area, which has concluded an administrative assistance agreement with France with a view to combating tax fraud and evasion, the allowance provided for in I of article 125-0 A is applicable under the same conditions. The limits of this allowance apply globally to the products defined in this paragraph and in article 125-0 A.

Gains on the sale of bonds or contracts are determined by applying the rules set out in article 124 C.

Mariela Petrova

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Common Questions

Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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