Dutreil pact: partial exemption from transfer duties raised from 50% to 75% and opened to gifts with reserved usufruct

Article 28 of Act No. 2005-882 of 2 August 2005 raises from half to 75% of their value the exemption from inheritance and gift duties on company shares (General Tax Code, Art. 787 B) and sole-proprietorship assets (Art. 787 C) transferred under a holding commitment. It removes the requirement to transfer full ownership: the exemption also applies to gifts with reserved usufruct, provided, for companies, that the usufructuary's voting rights are limited by the articles to decisions on the allocation of profits; it then cannot be combined with the duty reduction in Article 790.