A recently added article to the 2022 French Budget extends the scope of anti-tax avoidance rules, including some trust situations.

The French National Assembly recently added an Article to the 2022 French Budget, which aims at securing the application of preexisting anti-tax avoidance Article 123, in the context of certain French-connected trusts established in low-tax jurisdictions and which mainly hold financial assets.

The new measure will affect French tax resident settlers and beneficiaries, treated in France as “deemed settlers” where the original settler has passed. 

It introduces an automatic ...