Current Tax Developments - Unit Trust Manager

The French Administrative Supreme Court (Conseil d'Etat) decided on November 6, 1995, that the local business tax ("taxe professionnelle") special regime for business agents does not apply to the managers of Unit Trusts as defined by the law of July 13, 1979 ("Fonds communs de placement"). Indeed, a Unit Trust manager shall not be regarded as doing mediator activities, characteristic of a business agent. This decision terminates the frivolous litigation against Unit trusts managers that was aimed at determining a taxable base under local business tax (general turnover instead of tangible fixed assets and salaries), that was economically very unrealistic for Unit trust mangers activities.