Abolition of the tax on unrealised capital gains when moving tax residence abroad

Article 19 of the 2005 Finance Act repeals Article 167, 1 bis and Article 167 bis of the General Tax Code. These provisions, created in 1998, immediately taxed unrealised gains on substantial shareholdings when taxpayers resident in France for at least six of the last ten years moved abroad, with relief after five years if the shares were kept. The repeal follows the ruling of the Court of Justice of the European Communities of 11 March 2004. It applies to moves abroad from 1 January 2005.