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Inland
Revenue v Allen
This
recent House of Lords (England and Wales) decision relates to the
calculation of capital gains tax upon the sale of property held by an SCI
(société civile immobilière or special French property holding
company).
A potential individual capital gains tax liability may arise upon
the sale of French property that it owns when the shareholders are
resident in England and Wales.
This decision emphasises once more the fact that the use of
companies to purchase French property can raise taxation issues both in
France and abroad and requires careful consideration on the basis of the
individual situation.
Companies can be a Trojan horse: look wonderful but can bring all
kinds of difficulties!
05/12/2002
- Legal Update
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