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The Dutreil scheme: what the comments of 10 August 2026 clarify and what they leave unresolved


The Dutreil scheme: what the comments of 10 August 2026 clarify and what they leave unresolved

October 2026

Six months after the 2026 Finance Act, the authorities published their comments on the reform of the Dutreil scheme on 10 August 2026 in their bulletin BOI-ENR-DMTG-10-20-40, which addresses two issues: the exclusion of so-called ‘luxury’ properties from the basis for the partial exemption and the extension of the individual retention commitment. Practitioners will find in this bulletin often pragmatic clarifications, welcome flexibilities and a date of entry into force that takes existing circumstances into account. They will, however, search in vain for answers to several questions that are already requiring the settlement of transfer duties on transfers made without consideration.

In this article, Pascal JULIEN-SAINT-AMAND, Bérénice CERISIER and their co-authors present the clarifications provided by the tax authorities, accompanied by numerous examples, practical cases and diagrams.

This article is only available in French


Notary

Pascal JULIEN SAINT-AMAND - Althémis Paris

Pascal JULIEN SAINT-AMAND

Paris

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