The French Tax Authorities issued a ruling dated 28 December 2010 (RES n° 2010/71 (TCA)) regarding disposals of receivables made to refinance a financial activity. Disposals of receivables by a company within the context of its business, for instance the transfer of receivables by a factoring company to a securitisation fund or the sale by a bank of its receivables to another financial institution, fall within the scope of VAT but are VAT exempt pursuant to section 261 C of the French Tax Code, without any possibility to opt for VAT in accordance with section 260 C, 8° of the French Tax Code.