The first of the measures, which take the form of amendments tothe 2009 French budget law, is aimed at facilitating the creationof partnerships between listed real estate investment trusts (SIICs- Société d'Investissements Immobiliers Cotée) and OPCI non-listedopen-end funds (Organismes de Placement Collectif Immobilier).


Jointly held subsidiaries are entitled to opt for the taxtreatment applied to SIICs, which are exempted from corporation taxproviding they distribute a high percentage of income as dividendsto investors.Laurent Modave, of lawyers Gide Loyrette Nouel, saidthe change allows a SIIC to transfer property assets to asubsidiary in which it and a non-listed fund together hold at least95%.


It will also foster partnerships between several funds, whosejointly-held subsidiaries will also be able to opt for the SIIC taxregime. Dorian Kelberg, Executive Director of the FSIF listed realestate federation (Fédération des Sociétés Immobilières etFoncières), said the move will make it easier for listed companiesto carry out industrial projects.


The second measure concerns mergers between OCPIs and theirolder counterpart funds SCPI (Sociétés Civiles de PlacementImmobilier). In such cases the acquirer will be allowed to takeover any commitments by the acquired company to retain propertyassets for a period of five years. Such commitments are a conditionfor a reduced rate of corporation tax. Modave said this move willremove tax disincentives to restructuring by non-listed funds.

AllanSaundersonis a managing editor of Property FinanceEurope and a contributor to

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