Contribution-and-sale scheme: reinvestment requirement raised from 50% to 60% of sale proceeds

Article 115 of the 2019 Finance Act amends the tax deferral regime for gains on contributions of shares to a controlled company (Art. 150-0 B ter of the General Tax Code): if the contributed shares are sold within three years, the company must reinvest at least 60% of the proceeds (instead of 50%) within two years. Reinvestment may now take the form of subscriptions to FCPR, FPCI, SLP or SCR funds, to be held for five years. Applicable to sales of contributed shares from 1 January 2019. Article 11 of Law No. 2026-103 of 19 February 2026 (2026 Finance Act) raised the threshold to 70% and the reinvestment period to three years for sales made from 21 February 2026.