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In order to bring the French exit tax regime into compliance with the ATAD 1 Directive, the Finance Act for 2020 extends the optional capital gains tax splitting mechanism, hitherto reserved solely for transfers of registered offices and establishments, to transfers of isolated assets from France to an EU Member State or an EEA Member State. These provisions apply to transfers of isolated assets carried out during fiscal years beginning on or after January 1, 2020.

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