tax changes to come

 

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French Property News, July 2007

 

Since the recent election of Nicolas Sarkozy as the new French President in May 2007, his first measures seem to be in tune with the pre-election promises

 

An agenda has already been set up for his first 100 days in office despite the fact that he will not be in a position to start his new policies before the re-election of a new French Parliament in June, which will hopefully give him the majority he needs to drive the reforms France requires.  He and his ministers have already made some announcements on the tax side moving the country towards a more tax friendly and market orientated environment. 

 

Amongst the reforms Nicolas Sarkozy suggested is his 8 proposal to encourage French residents to become property owners of their homes.  He indicated that he will give incentives to encourage the building of new constructions and also allow the financial interest for those who need to borrow in order to purchase a property, to be offset against the overall household income.  On 24 May the minister in charge indicated that each household will be allowed to offset the loan interests up to 20% of their income.  This will apply only to the French residents as long as their title deed signed in front of the Notaire has been signed after the 6 May 2007, which is the date when Nicholas Sarkozy was elected President.  This tax allowance will be limited during a certain period of time which has not been confirmed yet. 

 

As part of the other proposals, which have been made a Minister confirmed the setting up of a tax shield ensuring that the amount of tax payable will not exceed 50% of the household income. This was particularly damaging for those assets rich and cash poor.  The current rules lay out the shield at 60% but does not include the additional 11% tax for social taxes which means that the new measure might reduce the tax by 21 points from 71% to 50%.  With the limitation to 50% this will substantially increase the French competitiveness.  In Sweden, Spain or Finland the current tax shield is 60%.  With the new rule France will join Germany, which since 1995 has limited its tax shield to the 50% in accordance with a Supreme Court decision, which declared anything above as against the German Constitution.

 

In addition, the households who invest in companies subject to conditions will receive a tax refund up to €50,000.  The new level of tax under the tax shield will continue to undermine the French Wealth Tax impact.  It is worth mentioning that those who do not complete their wealth tax forms by indicating that their assets are less than €760,000 and are therefore not subject to Wealth Tax are exposed to a ten-year prescription period during which the Revenue can challenge their tax position.  Those who have declared a taxable wealth are only subject to a three-year period.  

 

With regard to income tax and in order to encourage professionals to work extra hours and bring the country back to work the government has insisted that the working hours above 35 legal hours per week will have some tax allowances as well as the contributions payable by the employers on these extra hours.

 

We should hopefully hear of more incentives in the coming weeks such as the VAT at the reduced rate of 5.5% which should apply to restaurants although Nicolas Sarkozy might be willing to increase the general rate of VAT which is currently at 19.6% as Angela Merkel did for Germany. There will be certainly more to come.

 

 

For more information, please contact Christophe Dutertre in Blake Lapthorn's French Private Assets and Tax team on 023 9253 0379; email christophe.dutertre@bllaw.co.uk.