The Wealth-Focused Civil Company Subject to Corporate Tax

The civil company is created with an option for corporate income tax, an irrevocable choice that opens access to a much more favourable capitalisation tax regime than individual ownership. The founding shareholder contributes capital through a shareholder current account, a key mechanism that will later allow part of the income to be recovered without additional taxation.

From the outset, a split-ownership structure on the company shares is implemented for the benefit of the children. The shareholder retains the usufruct of the shares, and therefore the economic rights, while the children receive the bare ownership. This allocation, fixed from the beginning, is the core of the wealth transfer mechanism. Its strength lies in a highly efficient economic logic: bare ownership is transferred at a discounted tax value, calculated according to Article 669 of the French Tax Code based on the age of the usufructuary, while the company continues to capitalise and grow its assets year after year. The children therefore receive today, at a reduced cost, something that may be worth significantly more tomorrow: when the usufruct ends, they recover full ownership of shares whose real value may have been multiplied through capitalisation, without further taxation or additional duties on the accumulated gain.