Referring to a prior post, n°34, by way of reminder, any foreign entity, including a trust which purchases directly or indirectly an interest in French realty (immovable property) has to give either an undertaking to supply information on beneficial ownership to the French tax amdionstration on demand, or file an annual declaration. That has ben the law now for a long time.

However, the French tax administration are now requiring such entities, be they  corporate, some partnerships or trustees of a trust to apply for a French SIRET identification number. This used only to be required of French companies on incorporation. It is a form of legal, not Tax Identification Number. That number is of the esenc ein making the annual digital return.

This is not straightforward, and it is generally thought best that the foreign entity file an undertaking to supply information. without one month of its acquisition of the interest.

Note that, once given, if the undertaking is not honoured at any time then a declaration will be required, and at that point an application for a SIRET number may be required.

My advice has always been to favour giving an undertaking, which generallywill be followed up by a request for information every five or so years.

The declaration is an information gathering exercise for IFI purposes and for gift and succession duty purposes as these taxes operate on a form of interest lookthrough basis in relation to French land.

FDailure to fileof give an ujdertaking is subject to penalties and interest on the 3% tax which will be cnsidered to fall due from the 1st January of each undeclared year following the acquisition or last declaration or request fo information.

Please consult for advice on the best course of action to take, as whilst it is generally more favourable to give an undertaking, that is not always the case.