Section 0I bis: Tax on the market value of real estate owned in France by legal entities

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990 D990 E990 F990 G

Article 990 F

French General Tax CodeIn force
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Updated 7 Nov 2023

The tax is due on the property or property rights owned on 1st January of the tax year, with the exception of property duly entered in the inventories of legal entities operating as property dealers or developer-builders. Where there is a chain of holdings, the tax is payable by the legal entity or entities which, in this chain, are closest to the property or property rights and which are not exempt pursuant to d or e of 3° of article 990 E. Any legal entity, body, trust or comparable institution interposed between the debtor or debtors of the tax and the immovable property or immovable property rights is jointly and severally liable for the payment of this tax.

A legal person, body, trust or comparable institution which, failing to comply with the undertaking provided for in d of 3° of Article 990 E, has come within the scope of the tax provided for in Article 990 D, may exempt itself from the tax from the year in which it provides the tax authorities with the information referred to in the said d of 3° and makes a new undertaking to provide it subsequently at its request.

Taxpayers must declare by 15 May each year at the latest the location, composition and value of the properties and property rights in question. This declaration, accompanied by payment of the tax, is filed at the place set by order of the minister responsible for the budget.

The tax is collected according to the rules and under the penalties and guarantees applicable to registration duties. The provisions of article 223 quinquies A are also applicable to the tax.

In the event of a transfer of the property by a legal person, body, trust or comparable institution not established in another Member State of the European Union or in another State party to the Agreement on the European Economic Area which has entered into an administrative assistance agreement with France to combat tax evasion and avoidance and a mutual assistance agreement on tax collection, the representative referred to in IV of Article 244 bis A is responsible for payment of the tax remaining due at that date.

Mariela Petrova

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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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