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Supporting a financial institution with its tax and reporting obligations

We supported a financial institution wishing to offer its services to clients who are French tax residents and to manage equity savings plans.

By Cassandre Nogues, tax lawyer·Published ·Updated

The situation

It had to adapt its systems and procedures to the French obligations applicable to paying institutions, in particular as regards the IFU, return no. 2777 and the tax management of PEAs.

Our support

  1. 01

    Defining the tax treatment of products and transactions

    We analysed the various products and transactions offered by the institution in order to determine:

    • their tax characterisation in France;
    • the withholdings to be applied when income is paid or a taxable event occurs;
    • the information to be reported in return no. 2777;
    • the applicable boxes of the IFU (the annual single tax statement);
    • the supporting documents to be provided to clients.

    We then translated this analysis into a mapping file allowing the operational teams to link each product and each transaction to its tax and reporting treatment.

    Point of attention. The IFU summarises the investment income paid and the securities transactions carried out by the paying institution during the calendar year.
  2. 02

    Setting up the IFU and 2777 procedures

    We prepared the operational guides and tools required to enable the institution to:

    • collect and check the data relating to clients and transactions;
    • calculate the applicable withholdings and levies;
    • prepare and file return no. 2777 electronically;
    • produce the IFU data file for the tax authorities;
    • generate the individual IFU statements provided to clients;
    • identify and correct missing or inconsistent data;
    • handle corrective returns and client requests.

    Form no. 2777-SD must be filed electronically and accompanied by the corresponding electronic payment.

    In comparable engagements, our support has included reviewing the data, preparing the no. 2777 returns, producing the IFU statements and organising the annual reporting campaign.

    Point of attention. The challenge is to translate the French tax rules into operational processes that can be integrated into the financial institution’s systems.
  3. 03

    Securing the tax management of PEAs

    We also prepared a full guide on how the PEA (equity savings plan) operates, covering in particular:

    • the conditions for opening a plan and the holders’ eligibility;
    • the securities that may be held in the plan;
    • the monitoring of payments and of the plan’s value;
    • withdrawals and closures before or after five years;
    • the calculation of gains and applicable levies;
    • transfers between managing institutions;
    • the documents to be provided to the client or to the new institution;
    • the treatment of changes of tax residence.

    Tracking tools were created to keep the tax history of each plan, calculate the consequences of a withdrawal or closure and prepare the information required for return no. 2777 and the IFU.

The result

The financial institution was able to integrate the French tax rules into its internal procedures and IT tools.

It had an operational framework to manage the PEAs, apply the required withholdings, file the no. 2777 returns and produce the IFU statements for the tax authorities and its clients.

This case was handled by the firm, in light of the law and case law in force at the time of the engagement, and in the light of circumstances specific to it. It is presented for illustration purposes only: it does not constitute advice and does not predetermine the treatment that might be adopted in another matter.