Relaxation of the Dutreil pact: lower thresholds for the collective holding commitment

Article 40 of the 2019 Finance Act amends Article 787 B of the General Tax Code (75% exemption from gift and inheritance duties on business transfers). The collective holding commitment may cover at least 10% of financial rights and 20% of voting rights for listed companies (instead of 20% of financial and voting rights), and at least 17% of financial rights and 34% of voting rights for unlisted companies (instead of 34%). The text also allows a commitment made by a single person and relaxes the conditions of the 'deemed' commitment, contributions to a holding company and reporting obligations. Applicable from 1 January 2019.