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CAPITAL GAINS ON THE SALE OF SHAREHOLDINGS: ALMOST TOTALLY EXEMPT

Capital gains on the sale of shareholdings held for at least two years are totally exempt except for a 5% share corresponding to fees and

expenses.

A holding company realizes a net gain of €2,000,000 due to the sale of shareholdings held for at least two years.

Accounting profit:

€2,300,000

Non-accounting deduction of capital gains:

- €2,000,000

Non-accounting reinstatement of a proportionate share for fees and expenses (€2 M x 5% ):

+ €100,000

Taxable income:

+ €400,000

including €100,000 for the proportionate share of fees and expenses

Amount of corporate income tax ( 100,000 x 20%):

€80,000

of which corporate tax on capital gains: €20,000

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THE REDISTRIBUTION OF EARNINGS IS FREE FROM WITHHOLDING TAX

The amounts distributed by the company do not incur the payment of any withholding tax, regardless of the beneficiary (legal entity or

individual person) and their residency or place of effective management.

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BUSINESS TAXATION

DOING BUSINESS IN SAINT-MARTIN