TLDR: In France, certain categories of transactions, goods, or taxpayers are excluded from taxation in specific tax contexts. The main exclusions concern transactions involving investment gold (VAT exemption), certain categories of self-employed workers such as artist-authors (exemption from the cotisation foncière des entreprises), non-profit or retirement trusts (exclusion from the impôt sur la fortune immobilière), and self-supplies under specific conditions (non-subjection to VAT). These exemptions are governed by precise rules and have detailed conditions and limits.
Investment gold: VAT exemption
Transactions involving investment gold are generally exempt from VAT, with limited exceptions. Investment gold includes bars, ingots, wafers, and coins that meet the purity and form requirements set out in Article 298 sexdecies A of the Code général des impôts (CGI). The exemption automatically applies to sales to non-VAT registered customers and to intra-Community acquisitions or imports of investment gold. However, for sales between professional operators (B2B) involving bars, ingots, or wafers, taxation may be opted for. This option must be explicitly stated on the invoice with the mention "Application des articles 348 et 351 de la directive 2006/112/CE". Coins, on the other hand, cannot be subject to this option and remain always exempt.
Exemptions from cotisation foncière des entreprises (CFE)
Certain categories of self-employed individuals and activities are exempt from paying the cotisation foncière des entreprises (CFE). These include:
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Artist-authors, such as painters, sculptors, photographer-authors, and literary, dramatic, or musical authors, who sell exclusively the product of their art. The exemption is valid only if the activity is recognized as such by the Code de la sécurité sociale (Art. L. 382-1) and does not include the sale of other goods or services. Software authors are excluded.
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Educational institutions operating under a contract or agreement with the State, such as secondary schools, universities, and consular bodies.
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Occasional landlords who rent out part of their primary residence, provided that the rental is not periodic and the prices are considered "reasonable." For furnished rentals, the exemption may be excluded by specific municipal resolutions.
Partial exemptions for taxe foncière sur les propriétés non bâties
Land classified in categories 1–6 and 8–9 according to the ministerial instruction of December 31, 1908, benefit from a 30% partial exemption on the taxe foncière sur les propriétés non bâties. This reduction does not apply to land already fully exempt under other provisions of the CGI, such as Articles 1394 B, 1394 C, and 1395.
Exclusions from the impôt sur la fortune immobilière (IFI) for trusts
Certain trusts are excluded from the impôt sur la fortune immobilière (IFI) if they meet specific conditions:
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Irrevocable trusts whose exclusive beneficiaries are non-profit organizations, as defined by Articles 795 and 795-0 A of the CGI. The trustee must be subject to the law of a state that has an administrative assistance agreement with France to combat fraud and tax evasion.
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Trusts established to manage pension rights acquired by beneficiaries in a professional context, such as company pension schemes. In this case as well, the trustee must be subject to the law of a state with an administrative assistance agreement with France.
Livraisons à soi-même: cases of non-taxation of VAT
Livraisons à soi-même (self-supplies) are not taxed in three specific cases:
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If the upstream VAT was not deducted at the time of purchase of the goods or services.
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If the goods or services are intended from the time of purchase for non-business use, such as the private use of the owner.
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In the case of donations to associations recognized as being of public utility operating in humanitarian, educational, or social fields, according to Article 273 septies D of the CGI.
However, this exemption does not apply to real estate, which remains subject to global adjustments under Article 207 of Annex II of the CGI.