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Don't miss French property reporting deadline

13 March 2018

Many clients own a property in France, often through a Société Civile Immobilière (SCI).

A new French reporting obligation has been introduced for all non-listed entities registered with the Registre du Commerce et des Sociétés (RCS), including SCIs, in order to set up a French beneficial owner registry, in line with EU directive 2015/849.

Each entity must submit a report (forms DBE-S-1/DBE-S-bis/DBE-S-2) listing each beneficial owner (defined as the individual - not entities) who:

  • Holds (directly or indirectly) over 25% of the capital or voting rights in the structure; or
  • Exercises effective control over the entity's management or over the shareholders' AGMs; or
  • Directly or indirectly acts as the entity's legal representative(s), in the absence of any effective beneficiary.

This initial one-off reporting exercise must be completed no later than 31 March 2018 for all existing entities.

The report must be submitted to the Greffe du Tribunal du Commerce, accompanied by a payment of €54.42 (including VAT). Non-compliance or the filing of incomplete or incorrect reports may incur a €7,500 penalty and possible six months' imprisonment.

Any new entity must file the beneficial ownership statement within 15 days of its registration, with a payment of €24.80. The changes listed below must also be reported to the Greffe within 30 days, with a payment of €48.49:

  • Changes concerning the entity, such as a name change, new legal form or registered office;
  • Changes concerning the beneficial ownership, such as: removal or new appointment of beneficial owners, changes to any of the legal representatives initially reported as beneficial owners, changes to the forms of control exercised by the beneficial owner(s).

Please contact us for further information or assistance - we have French tax specialists within the firm who can provide advice or assistance on this matter.