II: Exemptions and special schemes.

Articles in this section · 12

Article 208 septies

French General Tax CodeIn force

Updated 8 Nov 2023

I. - Transfers of assets, rights and obligations carried out, at net book value, by a syndicat de défense des appellations d'origine constituted in the form of a syndicate governed by the loi du 21 mars 1884 relative aux syndicats professionnels ou d'association relevant de la loi du 1er juillet 1901 relative au contrat d'association, au profit d'un organisme de défense et de gestion mentionné à l'article L. 642-17 of the Rural and Maritime Fishing Code or an inspection body mentioned in article L. 642-3 of the same code, made necessary by the implementation of the article 73 of law no. 2006-11 of 5 January 2006 on agricultural guidance and the ordonnance n° 2006-1547 du 7 décembre 2006 relative à la valorisation des produits agricoles, forestiers ou alimentaires et des produits de la mer, ne donnent lieu à aucune imposition à l'impôt sur les sociétés.

For the determination of their taxable income, the beneficiaries of the transfers must comply with the provisions set out in a, b, c and e of 3 of article 210 A in respect of the assets, rights and obligations transferred to them. For the purposes of these provisions, the absorbed company means the entity that owned the assets, rights and obligations before the transaction took place, and the absorbing company means the entity that owns these same assets, rights and obligations after the transaction.

These provisions apply to transfers of assets carried out on or after 1 January 2007.

II. - Transactions involving the transfer of assets, rights and obligations carried out, at net book value, by an agricultural union recognised by the administrative authority as a producer organisation or agricultural economic committee for the benefit of a body that may be recognised by the administrative authority as a producer organisation or association of producer organisations in accordance with Articles L. 551-1, L. 552-1 and L. 552-4 of the Code rural et de la pêche maritime, and made necessary by the implementation of the article 53 of the aforementioned law no. 2006-11 of 5 January 2006, do not give rise to any corporation tax.

For the determination of their taxable income, the beneficiaries of the transfers must comply with the provisions set out in a, b, c and e of Article 210 A 3 in respect of the assets, rights and obligations transferred to them. For the purposes of these provisions, the absorbed company means the entity that owned the assets, rights and obligations before the transaction took place, and the absorbing company means the entity that owns these same assets, rights and obligations after the transaction.

These provisions apply to transfers of assets carried out on or after 7 January 2006.

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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