Deloitte Société d'Avocats

Beneficial owners to be treated as shareholders for the purpose of the French 3% tax on real estate

In a recent case law from the commercial chamber of the French Supreme Court (n°15-14528, SCI Katzoo) relating to a Luxembourg company with legal shareholders distinct from its beneficial owners, the Court specified that the company has fulfilled its filing obligations by disclosing only the economic beneficiaries’ identities and was thus entitled to the benefit of tax exemption.