Ruling by the Nantes Administrative Court of Appeal on tax avoidance schemes in overseas territories involving real estate investment companies (SCIs)
In a ruling issued last week, the Nantes Administrative Court of Appeal stated that taxpayers are eligible for the tax credit for the construction of new housing intended for social housing (Article 199 undecies C of the General Tax Code, also known as the “Girardin social”) when the investments are made through a partnership, particularly a real estate investment company (SCI).
The Court specifies, however, that "the proceeds from the offering of these securities must be fully invested within eighteen months of the closing of the offering. In all cases, the investment must take the form of the construction or acquisition of a residential building."