November 27, 2025
In February 2025, the regime applicable to gains from management packages, including the tax regime applicable to free share allocations (AGA), was substantially amended (Law No. 2025-127 of February 14, 2025, introducing Article 163 bis H of the CGI).
The tax authorities have provided further details on the application of the provisions of Article 163 bis H affecting this tax regime for free share allocations. The result is a rather complex regime, which can be better understood with the help of the following presentation.
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