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Exemption from CSG [General Social Contribution] and CRDS [social debt reimbursement contributions] on incomes from property and investment products for individuals subject to a health insurance schem

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08/12/2019
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Article 26 of the law 2018-1203 of 22 December 2018 on the financing of social security for 2019 has inserted a paragraph I ter into articles L136-6 (property income) and L136-7  investment products) of the Code de la sécurité sociale [French social security law], in order to achieve its compliance with the position of the CJEU following the “Ruyter” judgment.


It is thus now enshrined in law that individuals who are not subject to a compulsory French social security regime but are subject, in terms of health insurance, to a social legislation under the aegis of European regulation (EC) No. 883/2004, are exonerated from the contribution sociale généralisée (CSG) [General Social Contribution] and the contribution pour le remboursement de la dette sociale (CRDS) [social debt reimbursement contributions].  This concerns not only non-residents for French tax purposes, but also those who are resident for French tax purposes under a health insurance regime within the EEA, other than in France.


Exemption from CSG and CRDS concerns both incomes from property and from investment products. In consequence, only the solidarity levy at 7.5% remains applicable, with the exclusion of CSG and CRDS.


This partial exemption from social contributions is applicable :

- for incomes from property, as from tax on incomes from 2018 ;

- for investment products, for chargeable events occurring since 1 January 2019.


Being concerned solely with investment products, the decree No. 2019-633 dated 24 June 2019 which came into force on 26 June 2019, now specifies the arrangements for implementation of this exemption.


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Actualite title - Exemption from CSG [General Social Contribution] and CRDS [social debt reimbursement contributions] on incomes from property and investment products for individuals subject to a health insurance schem