Asset disposal to shareholders below market value: When an enterprise disposes of an asset to an individual shareholder or its affiliate up to the second degree or to his / her spouse in exchange for a consideration lower than its market value, the difference between the consideration and market value is considered to have been distributed as a dividend to the shareholder. This provision shall not apply to assets originally endowed in the company by an individual shareholder or a relative up to the second degree or his / her spouse.

Dissolution of the Company: The cumulative profits of the last five years prior to the dissolution of the company, which have not been distributed or considered to have been distributed, shall be deemed to be distributed upon dissolution and shall be subject to a Special Defense Contribution of 17%.

This provision shall not apply in the event of dissolution in the context of reorganization.

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