The French tax authorities have indicated in their guidelines that in a case of a partial sale of securities beyond the overall period of six years, the transferor loses the benefit of the tax exemption for all the securities (including those retained) for the year of the transfer and the subsequent years (BOI-PAT-ISF-30-40-60-20-20130522 n°150 dated 22 May 2013).

As a reminder, securities held by a taxpayer and subject to a lockup agreement (under certain conditions) are exempt from wealth tax up to 75% of their value.