French General Tax Code
In forceProvided that the members of the association resulting from the conversion are identical to the members of the converted company or body, that no changes are made to the accounting entries and that the taxation of profits, gains and capital gains not taxed at the time of the conversion remains possible under the new tax regime applicable to the association, the conversion of a company or body placed under the partnership regime defined in articles 8 to 8 terin an association of lawyers as referred to in article 238 bis LA subject to the same regime does not entail:
1° The consequences of the cessation of business provided for in article 202 ;
2° Taxation of the capital gain or capital loss arising on the cancellation of the shares in the converted company or organisation, the amount of which is added, when the time comes, to that of the capital gain or capital loss to be recognised in respect of the rights held in the association on the occasion of any transaction giving rise to the total or partial withdrawal of the member from the association, or the conversion or termination thereof within the meaning of articles 202 and 202 ter;
3° The taxation of previous deferrals, which are maintained until the deadline mentioned in 2°.
The first paragraph of V of Article 151 octies B applies to the member of the converted company or body until the deadline mentioned in 2°.
