Zoom sur le traitement fiscal applicable à une réduction de capital

The Council of State ruled in the following case: On October 1, 2002, Mr. A... contributed 175 shares he held in the capital of the public limited company Etablissements Berthold Marx et Cie to the civil law partnership (SC) Jennifer, which is subject to corporation tax and of which he and his wife are the sole shareholders. These shares had been acquired for a total price of €40,775. In return for this contribution, he received 105,838 shares of SC Jennifer, with a total value of €1,613,500, as well as €4.97 in cash.