In a recent decision (Conseil d’État, 12 March 2026, no. 497808, noted in the tables of the Lebon reports), the Conseil d’État confirmed the principle that the identity of the person liable for capital gains tax on the transfer of shares whose ownership is split between usufruct and bare ownership is fixed at the date of the transfer. Practitioners must therefore exercise particular care before completing the transaction.
Read the article by Hugues MARTIN and Anne-Sophie TORRES published in Les Nouvelles fiscales, no. 1403 of 1 September 2026, page 20, also available in French on the publisher’s website, Lamy Liaisons.
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