Do not lose one side that won on the other

Tax shield was, just before the crisis, a large topic. But, given the decline in prices of real estate, some people could no longer be subject to the ISF. Are all fiscal months not questioned

EDOUARD MILHAC. The tax shield is a strategy. We have seen some individuals implement tax shield with little heritage strategies. In the phenomenon of relocation, we saw first from the persons who had good reason to do so, then taxpayers who had especially an aversion to taxation, the grass is always greener on the other side of the border.

With the tax shield, we have seen the same phenomenon. It is a true heritage strategy when an important heritage and can control its revenues; the stakes are all significant cases. Today, we see individuals implement similar strategies without save large sums of money. Everything depends of course accept pay as tax. But I think that we too saw these last two years of tax shield strategies with which individuals pay more taxes and have more revenue. I do not find it healthy, because thus deferring the income there always a point where one must pay taxes.

Similarly, our clients ask us to respect the rule of 20 of units of account in their life that share in euros is not taxable income. Customers have integrated 20 units of account shares in their contracts to comply with this rule; It is unnecessary to say that they pay far more in latent losses than what they would have paid in ISF. Tax shield force taxpayers to take risky positions that they not on the other hand, would take which proves catastrophic for them somehow.

Today, the fiscal policy oriented more investment companies. Thus, the reduction of the ISF encourages investment in SMEs, which is a good measure. SMEs. This assistance is of the order of EUR 800 million for businesses; It is therefore impossible to return to this measure that would justify it only the existence of the ISF.

For life insurance, the situation is similar. In addition, the tax shield rule was not clear, she was known as, which was poorly experienced by our clients.

However, the tax Shield will perhaps find an attraction because of the 1.1 of additional assessment for the financing of the RSA. With all these measures, we can see that we are more than 50 of effective tax rate. Thus, the tax shield is a good measure that has helped many taxpayers to stay in France by paying an acceptable tax.

BERTRAND ENJOYED. Not to mention that he returns sometimes to harmonize the tax benefit and economic interest. This is true for the implementation of the tax shield but also for all heritage strategies on the structuring of real estate, Lai or estates. Do not the tax benefit to ruin the economic interest of the strategy. Do not lose one side that won on the other.

Do you have many clients who are fighting when they suffer a refusal to return to the title of the tax shield

EDOUARD MILHAC. Refunds were long to be put in place, but I find that recent applications have had very fast responses. In my opinion, this goes rather better. things are going in the right direction.

With the crisis, some countries among our neighbors will have to gradually raise their tax burden. The temptation of tax evasion may seem less relevant. What is your analysis

EDOUARD MILHAC. The fight against fraud has become a priority for the next few years. We have seen this year with what has happened between the Liechtenstein and the Germany. We are witnessing the return of the fight against fraud and legislators from all countries will provide the legal means to do this.

During the last decade, the decisions of the Council of State were rather favourable to the taxpayers. I think that we are in a period where the tax administration will be more hear. The judge decides course according to the law, but it is marked by its environment.