8°: Financial products benefiting international organisations, foreign sovereign States, their central banks or financial institutions

Articles in this section · 2

Article 131 sexies

French General Tax CodeIn force

Updated 8 Nov 2023

I. - Income from shares, corporate units or profit shares distributed by French companies, as well as income mentioned in article 118 which benefit international organisations, foreign sovereign States or the central banks of these States, are exempt from the withholding taxes provided for in 1 and 2 of l'article 119 bis et du prélèvement prévu au III de article 125 A.

These investments must not constitute a direct investment within the meaning of the loi n° 66-1008 du 28 décembre 1966 modified law relating to financial relations with foreign countries and the regulatory texts issued for its application. The securities must be in registered form or deposited with a credit institution established in France.

II. - With the approval of the Minister for the Economy and Finance, the withholding taxes provided for in 1 and 2 of Article 119 bis and the levy provided for in III of Article 125 A may be reduced or waived in respect of:

The products mentioned in I which benefit foreign public institutions;

The products mentioned in articles 124 and 1678 bis and those relating to investments constituting direct investments in France within the meaning of I which benefit international organisations, foreign sovereign States, the central banks of these States or foreign public financial institutions.

Mariela Petrova

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Common Questions

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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