The 2018 French Finance Bill was published on December 31, 2017 and is effective as of January 1, 2018. For more information on the key elements of the Bill, please see our October 2017 client alert and the Global Equity Equation Blog post, "ANOTHER French-Qualified RSU Regime on the Horizon."

The information in our alert and blog post remains accurate with the following small clarifications:

  • The employer social tax which is due at vesting of qualified RSUs granted under the new French-qualified RSU regime is due at a rate of 20% (reduced from 30% under the Modified Macron regime, and the same as under the Original Macron regime).
  • Shares acquired under an employee share plan could, in theory, be subject to the new real estate wealth tax, but only if the company issuing the shares holds directly or indirectly real estate. And even in this case, for shareholders who own less than 10% of the share capital of the company, it may be possible to obtain an exemption from the wealth tax liability. Therefore, in most situations, the real estate wealth tax will not apply to shares issued under an employee share plan.