Impact of proposed change in French Wealth tax on the 2011 Trusts régime

There is nothing palpable yet, but Président Macron’s proposal to convert the Impôt de Solidarité sur la Fortune or Wealth tax into a restricted tax on French high value immovable property will inevitably affect the 1.5% levy on Trustees, and possible also the reporting requirements. The 1.5% prélèvement or levy is a stick with which to beat trustees whose beneficiaries / settlors do not comply with the assumption that their interests whether fixed or discretionary are declarable for ISF under the 2011 régime. It is also a joint and several responsibility of the French residents or assetholders concerned.

However, the gift and succession duty aspects of the événementielle declarative procedure and article 750 ter CGI etc will undoubtedly be left in place to remain in undisturbed peace.

This is part of an overall review of the lifetime taxation of passive wealth, and there is also a proposition for a fixed income tax rate of 30% on passive investment income, which will undoubtedly be supplemented by the social contribution which has transmogrified the corresponding liability in the State’s balance sheet as one funded by a tax revenue rather than a delegated social security revenue.

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Peter Harris