I. (1) The products attached to warrants or capitalization contracts and to investments of the same kind taken out with insurance companies established in France are, at the time of the conclusion of the contract, subject to income tax.

The products in question are exempt, irrespective of the duration of the contract, when the contract is settled by the payment of a life annuity or if the outcome results from the dismissal of the beneficiary of the products or his early retirement or his disability or that of his spouse corresponding to the classification in the second or third category provided for in Article L. 341-4 of the Social Security Code;

The products in question consist of the difference between, on the one hand, the sums reimbursed to the beneficiary and, on the other hand, the amount of premiums paid, if any, since the acquisition of the voucher or contract, increased, in this case, the purchase price of the bond or contract.

Where the term of the bond or contract is equal to or greater than six years for warrants or contracts entered into between 1 January 1983 and 31 December 1989 and eight years for warrants or contracts entered into as from 1 January 1990, it shall be for all vouchers or contracts held by the same taxpayer, an annual abatement of € 4,600 for single, widowed or divorced taxpayers and of € 9,200 for married taxpayers subject to joint taxation on the sum of the acquired products. from January 1, 1998, or from the same date as for warrants or unit-linked contracts referred to in the second paragraph of Article L. 131-1 of the Insurance Code.

The abatement referred to in the fourth paragraph of this 1 ° applies as a priority to products attached to premiums paid before 27 September 2017, then, for products attached to premiums paid from the same date and when the option provided for in 2 of Article 200 A shall not be exercised, in respect of the fraction of such taxable income at the rate mentioned in 2 ° B of Article 200A, 1 and then to those taxable at the rate mentioned in 1 ° of the same B .

For the application of the deduction to the products attached to the premiums paid before September 27, 2017, when the option for the direct debit referred to in 1 of II of this article is exercised, the products are subject to the aforementioned levy for their gross amount, without the application of the abatement mentioned in the fourth paragraph of this 1 °. In this case, the taxpayer benefits from a tax credit equal to the rate of the said tax levied multiplied by the amount of the rebate not deducted from the products for which the option for this levy has not been exercised, retained in the limit of the amount of the products submitted to the said levy. This tax credit is deducted from the income tax due in respect of the year in which the deduction was made. If it exceeds the tax due, the excess is returned.

2 ° Partial or total conversion of a bond or contract mentioned in 1 ° of this I, whose premiums paid are allocated to the acquisition of rights that are not expressed in units of account mentioned in the second paragraph of the same article L 131-1, in a bond or contract referred to the same 1 ° of which a part or all of the premiums paid are allocated to the acquisition of rights expressed in units of account referred to above or rights giving rise to the constitution of a Diversification provision does not result in the tax consequences of an unwinding.

It is the same for :

a) Partial or total conversion of a bond or contract referred to in said 1 °, whose premiums paid are not allocated to the acquisition of rights that may give rise to the constitution of a diversification provision, in a bond or contract mentioned in the same 1 ° of which a part or the whole of the premiums are allocated to the acquisition of rights giving rise to the constitution of a provision of diversification. If the contract was converted in the six months preceding the conversion into commitments other than those expressed in units of account or giving rise to a provision for diversification into commitments expressed in units of account , only commitments other than those expressed in units of account or giving rise to the constitution of a diversification provision may be subject to the conversion referred to in the last paragraph of this paragraph;

b) The partial or total conversion of contracts falling under Chapter II of Title IV of Book I of the Insurance Code into a contract, a portion of which may be allocated to the acquisition of rights in euros.

The first paragraph and a of this paragraph 2 shall apply provided that the transformation results in the conversion of at least 10% of the commitments, other than those expressed in units of account or giving rise to a provision diversification, into commitments giving rise to the constitution of a diversification provision.

I. bis The products attached to the bonds or contracts mentioned in I for a period equal to or greater than six years for warrants or contracts entered into between 1 January 1983 and 31 December 1989 and eight years for warrants or contracts subscribed at from 1 January 1990, acquired on 31 December 1997 or recorded on the same date for warrants or contracts in units of account referred to in the second paragraph of Article L. 131-1 of the Insurance Code, are exempt from tax on income irrespective of the date of the payments to which these products relate. The same applies to the proceeds of these bonds or contracts relating to premiums paid prior to September 26, 1997, acquired or accrued as of January 1, 1998.

I. ter The income from the contracts referred to in Ia subscribed prior to 26 September 1997 is also exempt from income tax where such products, acquired or accrued as from 1 January 1998, relate to:

(1) premiums paid on periodic premium contracts not exceeding those initially provided for in the contract;

(2) scheduled payments made from 26 September 1997 to 31 December 1997; scheduled payments are those made pursuant to an undertaking prior to 26 September 1997 providing for the periodicity and the amount of the payment;

(3) other payments made from 26 September 1997 to 31 December 1997, provided that the total of these payments does not exceed 200,000 F per subscriber.

I. The products attached to the warrants or unit-linked contracts referred to in the second paragraph of Article L. 131-1 of the Insurance Code mentioned in I, of equal or greater duration, shall be exempt from income tax. at the age of eight, subscribed before 1 January 2005 and the unit of account of which is the unit or share of an undertaking for collective investment in transferable securities or a collective investment undertaking covered by paragraphs 1, 2 and 6 of the Subsection 2, of paragraph 2 or subparagraph 1 of subsection 1 of Subdivision 3 of Division 2 of Chapter IV of Title I of Book II of the Monetary and Financial Code, the assets of which consist of 50 % at least :

(a) Shares or investment certificates of companies and cooperative investment certificates admitted to trading on a regulated market for financial instruments included in the lists referred to in Article 16 of Council Directive 93/22 / EEC of 10 May 1993, concerning investment services in the securities field;

b) Rights or warrants attached to the shares mentioned in a;

c) Shares or units in undertakings for collective investment in transferable securities or collective investment schemes falling under subparagraphs 1.2 and 6 of subsection 2, subparagraph 2 or subparagraph 1 of subparagraph 1 of the Subdivision 3 of Section 2 of Chapter IV of Title I of Book II of the Monetary and Financial Code, which use more than 60% of their assets in securities and rights mentioned in a and b;

d) Units of risk-free mutual funds, specialized professional funds falling under Article L. 214-37 of the Monetary and Financial Code as drafted prior to Order No. 2013-676 of 25 July 2013 amending the framework asset management, private equity professional funds, proximity investment funds, innovation mutual funds, venture capital companies or innovative finance companies;

e) Shares issued by companies carrying out an activity other than the activities referred to in the second sentence of the first paragraph of I Article 44 sexies and whose securities are not admitted to trading on a regulated market;

f) Shares admitted to trading on a financial instrument market, whose operation is carried out by a market operator or an investment services provider other than a portfolio management company or any other similar foreign entity, or 'a State Party to the Agreement on the European Economic Area, issued by companies carrying out an activity referred to in Article 34 other than those referred to in the second sentence of the first subparagraph of Article 44e and whose the market capitalization is less than 150 million euros. Market capitalization is based on the average opening price of the sixty trading days preceding that of the investment. A decree issued by the Conseil d'Etat determines how this assessment is to be applied, particularly in the event of initial listing or corporate restructuring.

The securities referred to in (a), (b), (e) and (f) must be issued by companies whose head office is in a Member State of the European Union, or in another State Party to the Agreement on the European Economic Area which has concluded with the France an administrative assistance agreement to combat tax evasion and tax avoidance, and are subject to corporate income tax under ordinary law conditions at the normal rate or would be subject to the same conditions if the activity was exercised in France.

The securities mentioned in paragraphs (d), (e) and (f) must represent at least 5% of the assets of the undertaking for collective investment in transferable securities or collective investment falling under subparagraphs 1,2 and 6 of subsection 2 of paragraph 2 or subparagraph 1 of subparagraph 1 of subdivision 3 of section 2 of Chapter IV of Title I of Book II of the Monetary and Financial Code.

I quinquies.-1. The products attached to the warrants or capitalization contracts and investments of the same nature mentioned in I, subscribed from 1 January 2005 to 31 December 2013, of a duration equal to or greater than eight years and in which premiums paid shall be represented by one or more units of account consisting of units or shares of undertakings for collective investment in transferable securities, collective investment schemes falling under paragraphs 1 and 2 of subsection 2 of subsection 2 or subparagraph 1 of subparagraph 1 of subdivision 3 of Section 2 of Chapter IV of Title I of Book II of the Monetary and Financial Code or similar bodies established in another Member State of the Union European Economic Area, which has concluded an administrative assistance agreement with France for the purpose of combating tax fraud and tax evasion the mutual recognition procedure for approvals laid down in Council Directive 85/611 / EEC of 20 December 1985 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS), of which the asset is made up of at least 30%:

a. Shares that do not fall under Article L. 211-1 II of the French Monetary and Financial Code, admitted to trading on a financial instruments market, whose operation is carried out by a market operator or a service provider. investment services other than a portfolio management company or other similar foreign organization of a State Party to the Agreement on the European Economic Area;

b. Rights or warrants attached to the shares mentioned in a;

c. Shares or units in undertakings for collective investment in transferable securities and collective investment schemes referred to in the first paragraph, more than 75% of which are assets in the securities and rights referred to in a and b;

d. Units in risky investment funds or professional private equity funds that meet the conditions set out in Article 163d (II) B of the local investment funds referred to in Article L. 214-31 of the Code monetary and financial, innovation mutual funds mentioned in Article L. 214-30 of the same Code and shares in venture capital companies that meet the conditions laid down in Article 1-1 of the Law No. 85-695 of 11 July 1985 on various economic and financial provisions;

e. Shares or units issued by companies carrying on an activity mentioned in Article 34 whose securities are not admitted to trading on a French or foreign financial instrument market, whose operation is carried out by a market operator or an investment services provider or other similar foreign organization, provided that the subscriber of the bond or policy, his spouse and their ascendants and descendants do not hold together, during the term of the bond or contract, directly or indirectly, more than 25% of the rights in the profits of the company or did not hold such participation at any time during the five years preceding the subscription of the warrant or contract;

f. Shares admitted to trading on a market in financial instruments, the operation of which is carried out by a market operator or an investment service provider or other similar foreign organization, of a State Party to the agreement on the European Economic Area, issued by companies that carry on an activity mentioned in Article 34 and whose market capitalization is less than 150 million euros. Market capitalization is based on the average opening price of the sixty trading days preceding that of the investment. A decree issued by the Conseil d'Etat determines the methods of application of this valuation, particularly in the case of initial listing or corporate restructuring transactions;

g. Of units of funds or shares of companies mentioned in d, whose assets are more than 50% constituted in securities mentioned in e.

The securities and rights referred to in a, b, e and f must be issued by companies having their registered office in a Member State of the European Union, or in another State party to the Agreement on the European Economic Area having concluded with France an administrative assistance agreement to fight against tax evasion and tax avoidance, and which are subject to the corporate income tax under common law conditions at the normal rate or would be subject to the same conditions if they exercised their activity in France.

The securities referred to in paragraphs (d) to g must represent at least 10% of the assets of each undertaking for collective investment in transferable securities or collective investment falling under subparagraphs 2 and 2 of subparagraphs 2 and 6 or Paragraph 1 of Subparagraph 1 of Subdivision 3 of Section 2 of Chapter IV of Title I of Book II of the Monetary and Financial Code, the units or shares of which constitute the units of account of the bond or contract, the securities mentioned in and g representing at least 5% of this same asset.

The by-laws or articles of the undertakings for collective investment in transferable securities and collective investment schemes referred to in the first paragraph provide for compliance with the proportions of investments provided for in that paragraph and in the tenth paragraph. The same applies to the organizations and companies mentioned in c and g with regard to the proportions of investment mentioned in these same paragraphs.

2. Where undertakings for collective investment in transferable securities, collective investment schemes and the companies mentioned in the first subparagraph and in paragraphs (c) and (g) of 1, use forward financial instruments, repurchase agreements or any other transaction securities, these bodies or companies must comply, in addition to the asset investment rules provided for in 1, the minimum investment proportions mentioned in the first and tenth paragraphs and c and g of 1 , calculated by retaining in the numerator the value of the securities eligible for these proportions from which they actually receive the products. A Conseil d'Etat decree specifies the methods of calculation and the supporting documents to be produced by the organizations or companies concerned.

3. The warrants or contracts referred to in paragraph 1 may also provide that part of the premiums paid shall be used to purchase rights which are not expressed in units of account or which are expressed in units of account other than those referred to in paragraph 1. paragraph 1. For these bonds or contracts, the proportions of the investment to be respected by the unit of account referred to in the first paragraph of 1 shall be equal to the proportions provided for in the same 1 multiplied by the ratio between the premium paid and the part of that premium represented by the unit or units of account mentioned above.

I. sex A decree lays down the detailed rules for the application of I to I quinquies and in particular the reporting obligations of taxpayers and paying institutions.

II. 1. Natural persons who benefit from products mentioned in I attached to premiums paid until September 26, 2017 may opt for their deduction from a levy which releases the income to which it applies from income tax when the person which ensures the payment of these revenues is established in France, whether or not the debtor, the latter being established in a Member State of the European Union or in another State party to the agreement on Space European Economic Community with an administrative assistance agreement with France to combat tax fraud and tax evasion.

The option, which is irrevocable, is exercised at the latest at the time of receipt of the income.

The liberatory nature of the levy can not be invoked for the products which are taken into account for the determination of the taxable profit of an industrial, commercial, craft or agricultural enterprise or a non-commercial profession.

The rate of the levy is fixed:

a. 45% when the duration of the contract has been less than two years; this rate is 35%. 100 for contracts taken on or after January 1, 1990;

b. 25% where that duration was equal to or greater than two years and less than four years; this rate is 35%. 100 for contracts taken on or after January 1, 1990.

c. 15% when this duration was equal to or greater than four years.

d. 7.5% where the term was equal to or greater than six years for warrants or contracts entered into between 1 January 1983 and 31 December 1989 and eight years for contracts taken on or after 1 January 1990.

The duration of the contracts shall mean, for single-premium contracts and contracts involving the payment of regular periodic premiums, the actual duration of the contract and, in other cases, the weighted average duration. The weighted average duration provision is not applicable to contracts entered into after 1 January 1990.

2. The I and V of article 125 A are applicable to the products of bonds or capitalization contracts or investments of the same nature mentioned in I of this article or in the 6 ° of article 120, attached to premiums paid to count of September 27, 2017.

The levy rate applied to these products is fixed at:

a) 12,8 % ;

(b) 7.5% where the term of the contract has been equal to or greater than six years for warrants or contracts entered into between 1 January 1983 and 31 December 1989 and eight years for contracts taken on or after 1 January 1990.

This levy is not a discharge of the income tax established under the conditions provided for in Article 200A (1) or (2) and due to the income to which that deduction applied.

The levy is deducted from the income tax due in respect of the year in which it was operated. If it exceeds the tax due, the excess is returned.

II bis.-The levies mentioned in 1 and 2 of the II are compulsorily applicable to proceeds and gains of assignment of vouchers or contracts mentioned in I, the rates provided for in a to d of 1 of the same II or, for products or gains attached to premiums paid as of September 27, 2017, at the rate provided for in paragraph 2 of this same II, when they benefit persons who are not tax residents or who are not established in France.

The rate of such deductions is fixed at 75%, whatever the duration of the contract, when the products or earnings benefit persons who have their fiscal domicile or who are established in a non-cooperative State or territory within the meaning of Article 238-0 A.

The levies mentioned in the first paragraph of this IIa release the income to which they apply from the income tax or the profits tax.

However, where the beneficiary referred to in the same first paragraph is a natural person whose tax domicile is in a State or territory other than those referred to in the second paragraph, he may claim, by way of a claim submitted in accordance with the provisions of Article L. 190 of the book of the fiscal procedures, the benefit of the rate mentioned in the first paragraph of 2 ° B of the 1 of article 200 A of the present code under the conditions envisaged by this same 2 °. For the assessment of the threshold of € 150,000 referred to in 2 °, only the premiums on all the warrants or capitalization contracts as well as the investments of same nature underwritten by insurance companies established in France.

II ter.-The fraction having the character of products attached to bonds or capitalization contracts, as well as to products of the same nature, in particular life insurance contracts, sums paid by the Caisse des dépôts et consignations in application Articles L. 132-27-2 of the Insurance Code and L. 223-25-4 of the Code of Mutuality are subject to income tax determined in accordance with the taxation rules in force in the year of this payment or , if applicable, at the option of the taxpayer and for the only products related to premiums paid until September 26, 2017, the levy provided for in 1 of II of this article. The amount of taxable income is determined in accordance with the terms and conditions applicable on the due date of such warrants or contracts.

III. The levies mentioned in II and II bis are established, liquidated and recovered under the same guarantees and sanctions as that mentioned in Article 125 A. The provisions of Articles 242b and 1736 are applicable.

IV.-Insurance companies are required to provide the insured with all the information and documents enabling the insured to declare the products, if any, redeemed according to the tax regime applicable to them.

They also communicate this information to the administration. This declaration is made under the conditions laid down in Article 242b.

5.

1. For the application of 3 and by way of derogation from the provisions of this Code relating to　the taxation of capital gains, the proceeds resulting from the first transfer for a consideration of the same temporary usufruct or, if greater, the market value such temporary usufruct shall be taxable in the name of the transferor, a natural person or a company or group falling under Articles 8 to 8 ter, in the category of income to which, on the day of the transfer, the profit or income yielded or likely to to be procured by the good or right to which the temporary usufruct assigned

3を適用し、キャピタルゲインの課税に関するこの規範の規定を逸脱して、同じ一時的使用の検討のための最初の移転から生じる収入、またはそれよりも大きい場合は、市場価値そのような一時的使用は、譲渡人、自然人、または第八条から第八条までに該当する会社または団体の名義で、譲渡の日に譲渡された利益または所得一時的な使用権が割り当てられた財産または権利によって調達される

Where the temporary usufruct given relates to assets or rights providing or likely to provide income in different categories, the proceeds resulting from the transfer of such temporary usufruct or, where applicable, its market value, may be taxed in each of these categories. in proportion to the ratio between, on the one hand, the market value of the property or rights whose income is attached to the same class and, on the other hand, the total market value of the property or rights to which the temporary usufruct assigned .

付与された一時的な使用目的が、異なるカテゴリーの収入を提供する可能性のある商品または権利に関連する場合、そのような一時的な利用の移転に起因する収入または場合によっては、これらのカテゴリーに課税されることがあります。一方では、所得が同じクラスに所属する財産権または権利の市場価値と、他方では、一時的使用権が割り当てられた財産権または権利の総市場価値との比率に比例して。

2 °. For the application of 1 ° and failing to be able to determine, on the day of the transfer, a category of income, the proceeds resulting from the transfer of the temporary usufruct, or, as the case may be, its market value, is imposed:

2°。 1°の適用については、譲渡日に一時的使用権の移転に起因する収入、または場合によっては市場価値を決定することができない場合は、

(a) In the category of real estate income, without the application of Article 15 (II), where the temporary usufruct transferred relates to immovable property or shares in companies, groups or organizations, whatever in any form, not subject to corporation tax and predominantly immovable property within the meaning of section 150 UB or 244 bis A;

（a）不動産所得の範疇において、移転された一時的な利用物が不動産又は企業、団体又は組織における株式に関連する場合には、第15条（Ⅱ）いずれの形態においても、法人税およびセクション150 UBまたは244 bis Aの意味内の主に不動産の対象ではない。

b) In the category of movable capital income, when the temporary usufruct transferred is related to securities, rights, securities or rights relating thereto, or to securities representing the same securities, rights or securities, mentioned in Article 150-0 A;

b）移動資本収益のカテゴリーにおいて、譲渡された一時的使用権が、それに関連する有価証券、権利、有価証券または権利、または同種の有価証券、権利または有価証券を表す有価証券に関連する場合第１５０－０A条。

(c) In the category of non-commercial profits, in other cases.

（c）非営利利益のカテゴリーでは、他の場合。