There are limits to the cumulative discounts used to value SCI shares

A taxpayer was subject to a tax audit regarding the values reported for wealth tax purposes by several of his real estate investment companies (SCIs). Following the audit, he received a reassessment proposal the value of the shares in those companies.

The taxpayer challenged the valuation amounts for the shares determined byadministration , arguing that several discounts should have been applied when valuing the shares in the real estate investment companies (SCIs). 

In particular, it called for the application of discounts of:

• 10% for illiquid assets;

• 10% for illiquid securities;

• 10% for joint ownership, since he was not the sole shareholder of the real estate investment companies.

While the departmental conciliation board had approved the application of the first two reductions, the last one was rejected byadministration led to litigation in the courts.

In its ruling of July 9, the Court of Cassation held that the Court of Appeals had correctly ruled that the taxpayer could not, in addition to benefiting from the first two discounts, claim an additional discount "on the basis of an alleged joint ownership of the market value of his securities."

The taxpayer's appeal is therefore denied.

Court of Cassation, Commercial Division, July 9, 2025, No. 24-13.540, unpublished

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