TAX AND LEGAL

SGSS
GUIDES

WHAT TAXATION
FOR YOUR
FRENCH-SOURCE GAINS?

Non-tax residents in France

January, 2024

1
 French regulations (1) provide for a withholding tax on French-source benefits or gains
resulting particularly from the acquisition of free shares, the exercise of stock options, or the
exercise of warrants for subscription to business creator shares (French BSPCE) by employees
(or former employees) or executives in an international mobility situation who are not
domiciled in France for tax purposes at the time of the sale of the securities or of the
conversion to bearer form, if applicable.

The purpose of this guide is to describe the operating principles of this withholding tax and to
provide answers to the most frequently asked dealing with plans identified by the French
Commercial Code.

Il might be emphasized that all beneficiaries are affected by French-source gains, whatever
their tax residences are.

This guide describes the tax regime in force as of 1 January 2024. It does not cover the tax
treatment of French-source gains relating to “preference free shares”.

NEWS
2021 French Finance Law has abandoned the reform provided for by the 2020 and 2019
French Finance laws which aimed to modify non-resident taxation upon their French
source acquisition gains.
The specific withholding tax, which is partially final, on French source gains obtained
as part of an employee shareholding plan is thus maintained (1).

(1) Article 182 A ter of the French general tax code

2
 IN BRIEF

Understanding how French-source gain

and withholding tax (1) work

Mobility

Grant date Share acquisition Date shares can be Sale of

date sold shares
Activité exercée aux Etats-Unis
FREE (420 jours)

SHARES VENTE DES ACTIONS

Determination of the
acquisition gain and the 01/06/2013
French-source gain

REFERENCE PERIOD Deduction of the

Work performed Work performed in withholding tax on
outside France France the French-source
% of French- gain
source gain
French-source gain

Determination of exercise
gain and of the French-
source gain

STOCK
OPTIONS
Date of acquisition of Date stock options Sale of
Grant date stock options can be exercised shares

Mobility

Number of days of assignment in France (3)

FRENCH-SOURCE GAIN (2) = Acquisition gain X
Total number of days corresponding to the reference
period (work remunerated by the grant)

(1) In the context of French qualified plans, i.e., plans complying with the provisions of the French Commercial Code: stock options granted by companies in accordance with Articles L.225-177 to L.225-
186 of the French Commercial Code and free shares granted in accordance with Articles L.225-197-1 to L.225-197-6 of the French Commercial Code. For further information, please refer to SGSS Guide:
‘Why and how to determine a qualified/non-qualified stock option or free shares plan? What are the consequences?’.
(2) To calculate this ratio, the days not worked, including holidays and leave whatever the cause, are included in the numerator and denominator wherever the beneficiary was during these periods. You
have the option to demonstrate that this calculation method does not correspond to the reality of the distribution of your work and to determine the number of days actually worked, after consulting
and validating your employer through your usual HR contacts.
(3) The work remunerated by the granted securities and performed in France (or performed in another State but remaining taxable in France) must be assessed on the basis of 365 days/year.

3
QUESTIONS / ANSWERS

AM I Those affected are individuals who are not domiciled in France for tax purposes at the time of
the sale of the securities – as part of qualified plans with regard to the French Commercial Code
AFFECTED ? – and performed professional activity in France, in the capacity of employee or executive,
during the period of acquisition of the shares or the reference period determined by your
employer, if applicable.
The withholding tax applies to sales of securities carried out on or after 1 April 2011 on:
• securities resulting from exercised stock options granted since 20 June 2007 and
whose options have been exercised since 1 April 2011 (1);
• free shares acquired on or after 1 April 2011;
• warrants for subscription to business creator shares (French BSPCE) exercised since 1
April 2011.
As a French fiscal non-resident, you are required to declare to the French tax authorities any
earnings from French sources obtained as part of an employee-shareholding plan before
these dates.
Gains from free or performance shares granting placed in an employee share plan or gains
issued from stock-options financed with unavailable assets from an employee share plan,
provided that the shares have been kept 5 years, benefit from a tax exemption on income and
thus do not fall within the scope of the withholding tax.

For any additional information on the declarative terms of the latter, we invite you to contact:

Service des impôts des particuliers non-résidents

10 rue du Centre
TSA 10010
93465 NOISY-LE-GRAND - FRANCE

+33 (0)1 72 95 20 42
From Monday to Friday – 9.00 am till 4.00 pm

through your secured personal account on

website www.impots.gouv.fr

WHAT GAINS ARE Taxable gains on withholding tax are defined according to the employee share ownership
scheme from which they arise:
TAXABLE? • For stock options: the option exercise gain is the difference between the actual value of
the shares on the date of the exercise of the option and the purchase or subscription price
of the share (strike or exercise price), reduced, if necessary, by the excess rebate (1).
• For free shares: the acquisition gain equals the value of the shares on their final
awarding date, in other words at the end of the vesting period.
• For BSPCEs: the exercise gain results from the difference between the value of the
security subscribed on the date of the exercise of the warrant and the purchase price of
the security determined when the warrant is awarded.

(1) It should be noted that any excess discount offered at the time when the option is granted falls within the scope of withholding tax. It
represents additional pay and is taxed in the year that the option is exercised, in line with the rules on wages and salaries

4
WHAT IS THE Services rendered by employees are rewarded by the grant of shares as part of a given work
period: this is the reference period.
REFERENCE This period is determined by your employer based on specific circumstances, particularly
specified in contractual documents such as plan regulations, award letters, etc.
PERIOD? In practice, in the absence of clarifications in contractual documents or sent by your employer,
Société Générale will consider the work justifying the grant of securities to be work performed
between the grant date and the date on which the beneficiary becomes owner of the
Reference securities:
period
• for stock options: the date of final acquisition of the options;
• for free shares: the date of final acquisition of the shares;
• for BSPCE: the date of exercise of the warrant.

The withholding tax applies on French source acquisition gains from employee shareholders
schemes, e.g. gains coming from the grant of shares to employees on preferential terms in
return of their professional activity in France.
The withholding tax exclusively applies on this part of the acquisition gain which remunerates
professional activity in France.

If the granted securities are gradually acquired, the reference period must be
assessed by acquisition tranche.
When the final acquisition of the options or rights is subject to one or more
conditions precedent (performance conditions of the company or the employee,
presence conditions, etc.), the reference period can run from the grant date of the
option or right to the day when these conditions are met.

WHAT IS A The fraction of the French-source gain is determined by your employer in proportion to the
number of days of work performed in France during the reference period:
FRENCH-SOURCE
GAIN? Total amount of the acquisition gain X Number of days of
assignment in France
corresponding to the work remunerated by the grant of shares
performed in France (or performed in another State but
FRENCH-SOURCE
remaining taxable in France)
GAIN =
Total number of days
corresponding to the reference period
(work remunerated by the grant)

In this context, your employer defines, according to a calendar year breakdown (365 days per
year) by referring to the commencement date of employees assignments in France, the
number of days worked in France by its employees.

5
WHEN AND BY The withholding tax is applied at the time of the sale of the securities resulting from the
exercise of stock options, the acquisition of free shares, or the exercise of warrants, on the
WHOM IS THE acquisition/exercise gain, or at the time of their conversion to bearer form.

WITHHOLDING TAX Société Générale is legally liable for the withholding tax based on information communicated
by your employer, within the framework of plans qualified according to the provisions of the
LEVIED? French commercial Code.

In accordance with French regulations, Société Générale individually and nominatively

declares French-source gains you realized and pays the corresponding amount of tax
each quater to the French tax authorities for sales in the previous quarter.

It is Société Générale’s responsibility to calculate and collect withholding tax, declare it and
redistribute it to the public treasury.
If the tax has not been withheld, legislation provides that Société Générale is allowed to claim
for reimbursement from the beneficiary of the withholding tax, if applicable.

ON WHICH BASIS Withholding tax rates apply to the net amount of the taxable gain, after the application of
allowances, where applicable.
IS THE  You may benefit from an allowance for a holding period only on free shares whose

WITHHOLDING awarding was authorized by a decision of the Extraordinary General Meeting of the
company as of 8 August 2015, as well as for free shares whose awarding was authorized by
TAX RATE a decision of the Extraordinary General Meeting as of 31 December 2016 within an annual
limit of €300,000 (1), under the following conditions:
APPLIED? Security held for % allowance
Less than 2 years 0%
2015
2 years ≤ duration < 8 years 50 %
Equal to or more than 8 years 65 %
2018

 For free shares granted by decision of an Extraordinary General Meeting AS OF 1 January

2018 and only for the fraction of the annual acquisition gain of €300,000 or less, a 50 % fixed
allowance is applicable without any holding period condition (2).
The 10% allowance for professional fees is also applicable for:
• the free shares awarded by decision of an Extraordinary General Meeting prior to 8
August 2015, or by decision of an Extraordinary General Meeting as of 30 December 2016
for only the fraction of the annual acquisition gain exceeding a limit of €300,000;
• the stock options that they have been awarded prior to or as of 28 September 2012.
No deduction for actual and justified expenses can be made.

The application of these rates also implies that the account-keeper takes into account all
the gains already made and subject to withholding tax during the same year.

(1) Gains in excess of this limit will not be eligible for the allowance for the holding period and will be taxed according to the salary and wages
system at the prevailing rates and conditions.
(2) The portion of the acquisition gain may also be reduced by the fixed allowance of € 500,000 for retired executives, if applicable (Article 150-0
Db of the French General Tax Code).

6
WHAT IS/ARE
THE WITHHOLDING TAX RATE(S)?
STOCK-OPTIONS AND FREE SHARES: for plans granted BEFORE 28 september 2012

Proportional rates Wages and

(default regime) (1) salaries regime (1)(2)
Holding of shares 18 % (gains ≤ 152 500€)
Compliance with > 2 ans et 30 % (gains > 152 500€) Or,
tax lock-up 0 % for gains
STOCK- Holding of shares 30 % (gains ≤ 152 500€) as an option
period (4 years) less than €16,820
OPTIONS < 2 ans et 41 % (gains > 152 500€)
Non-compliance with tax lock-up No taxation at the proportional rate / 12 % for gains
period (4 years) the wages and salaries regime applies by default between €16,820 and €48,792
Compliance with holding period
30 % Or, as an option 20 % for gains
FREE (2 years)
greater than €48,792
SHARES Non-compliance with holding No taxation at the proportional rate /
period (2 years) the wages and salaries regime applies by default

If you sell your free shares within two years following their acquisition, as
part of a free share plan without a mandatory share holding period, you will
be automatically subject to withholding tax at the rate(s) provided for by the
“Wages and salaries” regime.

STOCK-OPTIONS AND FREE SHARES: for plans granted AFTER 28 september 2012

Wages and salaries regime (1)

STOCK-OPTIONS 0 % for gains less than €16,820
& 12 % for gains between €16,820 and €48,792
FREE SHARES 20 % for gains greater than €48,792

All gains from acquisition and exercise of options already realized and
subject to the withholding tax during the same year will be taken into
account by Société Générale in order to determine the tax bracket to be
applied for the withholding tax.

WARRANTS FOR SUBSCRIPTION TO BUSINESS CREATOR SHARES (FRENCH BSPCE)

Proportional rate of 19 % (activity ≥ 3 years in the company)

BSPCE granted BEFORE 1 January 2018
Proportional rate of 30 % (activity < 3 years in the company)
Proportional rate of 12.8 % (activity ≥ 3 years in the company)
BSPCE granted ON OR AFTER 1 January 2018
Proportional rate of 30 % (activity < 3 years in the company)

Any capital loss recorded when the transfer price of the securities is below
their value on the date of exercise of stock options, the acquisition of free
shares, or the exercise of BSPCEs is not deductible from the taxable benefit
in France.

(1) On condition that the employee is not a resident in a non-cooperative state or territory (NCST), for which the withholding tax rate is 75 % (discharging of income tax and, non-refundable withholding
tax); the list of these Countries and Territories is published annually in a decree (last list of these NCST published in February 2023 available on website legifrance.gouv.fr), and provided that the
professional work is not performed in the Overseas Departments, in which case the rates of 12 % and 20 % are reduced to 8 % and 14.4 %.
(2) Withholding tax rates apply to the net amount of the taxable gain, after application of allowances, where applicable.

7
WHAT ARE THE
TERMS OF
THE TAX OPTION?
If you already expressed your tax
choice in 2024, it will be valid for all
future sales over the 2024 tax year,
based on your cumulative French-
source gains realized.
WHAT SUPPORTING
DOCUMENTS WILL
BE SENT TO ME?
These supporting documents
must be kept as part of your
income tax return relating to
the year in which the gains
from the exercise of stock
options or BSPCE and/or the
acquisition of free shares are
reported (see table opposite)
in respect of the year in which
the shares were disposed of.
We invite you to save these
documents.
WHAT IS THE
IMPACT OF THE
WITHHOLDING TAX
ON THE
SETTLEMENT OF
MY OPERATIONS?
You have the possibility of opting for the application of a withholding tax according to the
wages and salaries regime instead of taxation, by default, at the proportional rates.
This option is possible only for transactions carried out on free share or stock option granted
before 28 September 2012, provided that any mandatory holding/lock-up periods are
respected (see table “Plans granted before 28 September 2012” in the previous question: “What
is/are the withholding tax rate(s)?”).
This option is annual: the choice made at the time of the first sale is then applied to the other
sales made during the financial year under consideration for all transactions (stock options and
free shares). It will therefore need to be renewed each year.
If no option is expressed to SGSS, which previously got in contact to collect your tax choice,
the proportional rates will apply by default.
A retrospective option is possible, exclusively through the filing of an income tax return in the
year following the transfer of the shares, by your own care. The tax authorities will therefore
determine the methods of recovering the income tax due, if applicable.
You will receive from Société Générale, or from your employer, if applicable, the following tax
statements, each mentioning the total acquisition of free shares, exercise of stock options or
exercise of BSPCEs gain as well as the share of the French-source acquisition of free shares,
exercise of stock options or exercise of BSPCEs gain:
Type of Date of sending and/or Year of declaration of
attestation available on Sharinbox gains
Beginning of the year following Year of sale of the securities
STOCK Certificate of
the exercise of your stock resulting from the exercise of
OPTIONS exercise
options your stock options
Beginning of the year following
FREE Certificate of
the final acquisition of your free Year of sale of your free shares
SHARES acquisition
shares
Certificate of Beginning of the year following Year of sale of the securities
BSPCE
exercise the exercise of the BSPCEs acquired by exercising BSPCEs
You will also receive from Société Générale a notice of operation indicating the amount of the
withholding tax levied following your operation, a tax summary following the sale of your
shares and a certificate of declaration and payment withholding tax which sums up all the
withholding taxes at source applied for the relevant tax year.
The documents shall be available, if necessary, on www.sharinbox.societegenerale.com
under the “My documents / My statements” tab on your account.
The deduction of this withholding tax involves a delay in the processing of your settlement
associated with the determination of its amount.
Depending on the case, Société Générale must be provided with information from your
employer, carry out the calculations of the withholding tax paid, according to the existing tax
regimes, add up your French-source gains based on any previously performed sales, calculate
the tax on the financial transactions, where applicable (1), and ask you about your tax option, if
applicable, for plans granted before 28th September 2012.
(1) The financial transaction tax pertains only to exercises of stock options for an exhaustive list of companies set by annually by the French tax
authorities and exclusively on share purchase plans.
8
WHAT IS After a merger or acquisition, share options of an absorbed or acquired company might be
replaced by options on the shares of the successor or which acquires.
THE IMPACT  Before the exercise of stock-options or acquisition of free shares, the operations of fusion
IN THE EVENT OF and spin-off realized in France in particular can be considered “intercalary” said operations
to appreciate the countdown of the deadline of unavailability in case of exchange of options
AN EXCHANGE or rights.

TRANSACTION  After the exercise of stock-options or acquisition of free shares, the exchange without a cash
balance of shares from options is not considered as a sale with regard to the system of the
DURING A options on shares resulting from an operation of a public bid, merger, spin-offdemerger,
split, consolidation or from contribution to a company created under certain conditions (1)
RESTRUCTURING for the options attributed until September 27th, 2012 and for the options attributed as from
September 28th, 2012 (2).
OF THE COMPANY? In case of realization of one of these operations, the conditions relating to the nominative
character and unavailability continue to apply to the shares received in exchange.

These complex cases are based on a specific analysis on which it is recommended to seek the
support of your tax adviser.

AM I LIABLE FOR Yes, in some cases.

A SUPPLEMENTARY As indicated in the table below, the withholding tax deducted may not provide full discharge
from French income tax liability.
TAX IN FRANCE? In cases in which the withholding tax does not provide discharge from other tax liability, a
supplementary tax may be due based on the beneficiary's income level and family situation (3).
For the year of the sale, you will then need to fill out form 2041 E (4) “Déclaration de retenue à la
source année 2022” as well as declaration 2042 with all information pertaining to your
identification as a taxpayer. Depending on the assets held, you will also need to complete your
declaration 2042 C according to the procedures described below.

The French tax authorities will use this as the basis for determining the amount of any
supplementary income tax due.

In the event that the withholding tax exceeds the amount of income tax calculated, this surplus
shall be reimbursed.

Withholding tax does not affect your reporting requirements for establishment of income tax
due in France and has no impact on the requirements concerning other taxes payable.

For example, the 10 % specific salary contribution applicable to stock options gains (in case of
exercises of stock options realized thanks to unavailable assets of Plan d’Epargne Entreprise
included) and free share gains from plans granted after 16 October 2007 (3) may apply if you are
covered by a French medical coverage scheme.

It is your responsibility, mandatorily, to declare your earnings from French

sources to be liable for the specific salary contribution of 10%.

(1) Article 220 nonies of the French General Tax Code

(2) Article 80 bis of the French General Tax Code
(3) If the beneficiary domiciled outside France is affiliated with a French mandatory health insurance scheme, the amount of gains from
exercising options on securities or free shares granted on or after 16 October 2007 must, in all cases, be reported on line 3 VN of declaration
2042 C for the calculation of the employee contribution (10%). %). The 10% specific salary contribution do not apply to acquisition gains
from free or performance shares granted upon Extraordinary General Meeting from 8 August 2015. 2015, except for free or performance
shares granted upon Extraordinary General Meeting from 31 December 2016 and for the only fraction of the gain exceeding an annual limit
of 300 000 €.
(4) Declaration 2041-E is intended for users residing outside France who may be subject to French tax.

9
CONCRETELY,
WHICH DECLARATIONS AND BOXES SHOULD I FILL OUT?
SUPPLEMENTARY DECLARATION PROCEDURES (Declaration 2042 C 2023 Incomes 2022)
Tax regime /
Withholding tax
Gain rate Type of taxation Supplementary declaration procedures (*)

• carry-forward gain on Stock-options exercised: declaration 2042 C – box 3 – 3VD, 3VI or 3VF
• carry-forward withholding tax amount deducted : declaration 2042 K – box 8 – 8TA « Non-
Proportional rate (1) Non-discharging for income
STOCK-OPTIONS

résidents : Retenue à la source prélevée en France. Report de l’annexe n° 2041 E » (3)

18 %, 30 % or 41 % tax in France
• carry-forward gain on Stock-options exercised under salary contribution (10 %) where
applicable and solely for options granted from 10/16/2007: declaration 2042 C – box 3 – 3VN

Discharging for the fraction of • carry-forward gain on Stock-options exercised without deduction of the discharging fraction:
declaration 2042 C – box 3 – 3VJ / 3VK
the gain taxed at 0 % and 12 %
Wages and • carry-forward withholding tax amount deducted: declaration 2042 K – box 8 – 8TA « Non-
salaries rate Non-discharging for the résidents: Retenue à la source prélevée en France. Report de l’annexe n° 2041 E » (3)
0 %, 12 %, 20 % • carry-forward gain on stock-options exercised without deduction of the discharging
fraction of the gain taxed
fraction of employee contribution (10 %) solely for Stock-options granted from 10/16/2007,
at 20 % where applicable: declaration 2042 C – box 3 – 3VN

• carry-forward gain by free shares acquisition : declaration 2042 C – box 3- 3VI

• carry-forward withholding tax amount deducted : declaration 2042 K – box 8 – 8TA « Non-
Proportional rate (2) Discharging for income tax in
résidents: Retenue à la source prélevée en France. Report de l’annexe n° 2041 E » (3)
FREE SHARES

30 % France • carry-forward gain by free shares acquisition under salary contribution (10%), where
applicable: declaration 2042 C – box 3 – 3VN (4)

Discharging for the fraction of • carry-forward gain by free shares acquisition without deduction of the discharging fraction
the gain taxed at 0 % and 12 % : declaration 2042C – box 3 – 3VJ / 3VK
Wages and
• carry-forward the withholding tax amount deducted: declaration 2042 K – box 8 – 8TA « Non-
salaries rate Non-discharging for the résidents: Retenue à la source prélevée en France. Report de l’annexe n° 2041 E » (3)
0 %, 12 %, 20 % fraction of the gain taxed • carry-forward gain by free shares acquisition without deduction of the discharging
at 20 % fraction for salary contribution (10%), where applicable: declaration 2042 C – box 3 – 3VN (4)
BSPCE

• carry-forward gain on BSPCE exercised: declaration 2042 C – box 3 – 3SJ, 3TJ or 3SK
Proportional rates Discharging
• carry-forward withholding tax amount deducted : declaration 2042 K – box 8 – 8TA « Non-
12.8%, 19% ou 30% for income tax in France résidents : Retenue à la source prélevée en France. Report de l’annexe n° 2041 E » (3)

(*) Global amount of French and foreign source incomes to be reported in case of choice to benefit from average rate of tax instead of the minimum taxation of 20 %:
declaration 2042 – box 8 – 8TM “Non-résidents: Revenus de source française et étrangère retenus pour le calcul du taux moyen”.
The block "Eléments complémentaires" of the declaration 2042 K should include the nature and amount of each category of income.

Selection after the fact for taxation of gains in the “Wages and salaries” category is possible through
your income tax return in the year following the sale of your shares, without Société Générale's
involvement (5).

(1) This arrangement is intended for stock options granted between 20 June 2007 and 28 September 2012.
(2) This arrangement is intended for free shares granted before September 28, 2012.
(3) Withholding tax in France, e.g. 2041-E annex, or tax paid outside France, upon 2047 declaration report.
(4) This salary contribution applies when the beneficiary is affiliated to a French mandatory health insurance scheme on the date of share transfer. Gains by free shares acquisition allocated as of 09/28/2012
(i.e. date of allocation) and prior to 08/08/2015 (i.e. date of the Extraordinary General Meeting (EGM) decision authorizing such allocations), and also allocated with effect from 12/31/2016 (i.e. date of the EGM
decision authorizing such allocations) and only for the fraction of the gain above an annual limit of €300,000, are automatically subject to this contribution. Thus, it’s not necessary for you to report your gain
on the 2042 C declaration in box 3 – 3VN.
(5) BOI-IR-DOMIC-10-20-20-40 (§ 240 and next).

10
IN PRACTICE,  In the event of application of proportional rates, you must state, on annual income
declaration form no. 2042 (CERFA no. 10330), available from the website
WHAT IS www.impots.gouv.fr in the “Form Search” section, the total amount of gains originating in
France as a result of securities transactions taxed at proportional rates achieved during the
THE IMPACT year, as well as other income originating in France received by you during the year.
The withholding tax relating to these gains shall be allocated to the amount of income tax
ON MY INCOME TAX calculated for all your income originating in France.

IN FRANCE? In general, this operation is therefore neutral and does not result in any additional
deduction.
However, when the total amount of gains achieved during the year exceeds the threshold of
152,500 euros, an income tax supplement will be recorded.
TAX  In the event of application of the rates stipulated in relation to “Wages and Salaries”, you
must state, on annual income declaration form no. 2042 (CERFA no. 10330), available from
? the website www.impots.gouv.fr in the “Form Search” section, the fraction of gains
originating in France as a result of employee share ownership provisions taxed at 20%
during the year, as well as other income originating in France received by you during the
year.
The 20% withholding tax relating to these gains is not deducted from the amount of gains
declared but is allocated to the amount of income tax calculated for all your income
originating in France.

CAN THERE BE A Yes.

Any double taxation may be eliminated under the conditions stipulated by the tax treaty in force
DOUBLE TAXATION between France and your country of residence for tax purposes. Depending on the case, the
double taxation elimination clause will apply the progressive exemption method or the tax
BETWEEN THE credit allocation method.

WITHHOLDING TAX In all cases where the mechanisms for elimination of double taxation provided for by the tax
agreements prove insufficient, you have the possibility of submitting a request to the French tax
IN FRANCE AND THE authorities for the opening of an amicable procedure.
• You performed work in only one State
TAX DUE IN MY The exercise gain or a similar gain is exclusively taxable there.

COUNTRY OF • You performed work in several States

If, during the reference period, you worked in several States and the corresponding
RESIDENCE? remunerations were subject to tax there, the taxation on the corresponding gain must
be distributed between them in proportion to the number of days during which these
services were provided in each of them.
If you encounter any difficulties in the application of these provisions, you have the possibility
of contacting your usual contact at the French tax authorities, for example, through your tax
center.

WHO CAN I The French tax authorities can be contacted, in France.

Any eventual difficulties which may arise from the application of provisions concerning the
CONTACT IN CASE methods of taxation on capital gains may be brought to the attention of the authorities at the
followings:
OF DIFFICULTY
CONCERNING THE Direction Générale des Finances Publiques
Direction de la Législation Fiscale (DLF)
TAXATION OF THIS Sous-direction C - Bureau C1
139 rue de Bercy - Télédoc 571
TYPE OF CAPITAL 75542 PARIS Cedex 12 - FRANCE

GAIN? bureau.c1-dlf@dgfip.finances.gouv.fr

+33 (0)1 53 18 90 16
+33 (0)1 53 18 91 16

11
This communication contains general information pertaining to qualified plans within the meaning of the French Commercial Cod e and is provided for
information purposes only. The items that may be described in it, particularly the principles for determination of French-source gains, tax selection, etc., pertain
to qualified plans only. The indicated rates and scales are those in force as at 1 January 2024 and may change based on developments in French legislation.
This communication is inseparable from the contextual elements that permitted its preparation and the accompanying comments o r publications.

This document does not detail the specific regulations that may apply to your particular case, particularly in view of the foreign social contributions likely to be
also applied to your operation(s) and can therefore under no circumstances be considered as representing legal or tax advice or a notification or
recommendation by Société Générale. If you are not subject to the tax or legal regime presented in this document, the information that it contains may not be
applicable to you. Furthermore, it is highly recommended that you seek professional advice for any tax-related or regulatory questions that you may have
relating to your situation.

The information presented is subject to local or international regulatory changes, which may be implemented at any time.
Furthermore, Société Générale may not be held responsible for the veracity, the accuracy and the completeness of the informat ion presented, nor for any
consequences linked to the use of its content. Société Générale cannot be held liable for any loss or damages that may direct ly or indirectly result from the
contents of this document or the use made of such contents.

This disclosure is published by Societe Generale. A limited liability company with capital of EUR 1 003 724 927,50 on 17 November 2023.
Registered in the Paris Trade and Companies Register under unique identification number B 552 120 222 - SIRET number: 552 120 222 00013.