OPCI, tax treatment
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OPCI, tax treatment

The analyses on this website reflect our understanding of the current French Tax Law. We draw investors’ attention to the informative nature of the following developments, to the fact that they do not constitute any contractual offer, to the necessity for investors to consult their own counsel in order to verify if this tax treatment would apply to their personal situation, and to the fact that these are subject to change in time.

OPCIs are corporate income tax-exempt; their distributions are made in the form of dividends. Tax can be triggered and levied at shareholder’s level upon dividend distribution. SPPICAV are required, however, to fill in annual corporate tax and VAT returns.

OPCIs with an FPI status (“Fonds de Placement Immobilier”) are transparent entities. Unitholders are therefore taxable as if they were holding the assets of the Fund directly.

If a corporate tax liable company converts into a SPPICAV, tax exemption can be granted provided a 19% exit-tax is paid on latent capital gains (up to 21.03% if the exceptional 10% contribution applies). Exit tax is payable in four annuities.