France And Jersey Tax Agreement

French 3% Real Estate Tax Exemption

France and Jersey entered into a tax information exchange agreement (TIEA) on 23 March 2009. Jersey has previously entered into similar agreements with 11 other OECD countries.

One of the key benefits of the TIEA with France is that Jersey investment funds and real estate holding structures will qualify for exemption from the French 3% real estate tax which is assessed annually on the fair market value of the real property situated in France. The exemption also extends to interests, shares and units in certain intermediate structures holding French real estate assets. An extract from the text is set out below:

• "Subject to compliance with certain reporting obligations (information on the entity's owners and assets), the 3% tax will apply neither to entities with legal personality owning directly or indirectly one or more buildings in France or owning real property rights to such assets, provided that their registered office is