Prior to browsing this website, please carefully read the disclaimer below. It indicates certain restrictions imposed by regulations regarding the dissemination and use of the information presented regarding the products and services offered by Private Corner.
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The information contained on the pages of this site is solely intended to present the expertise of Private Corner in the field of unlisted asset management.
They are not intended to:
- provide an exhaustive presentation of alternative investment funds (hereinafter referred to as "AIFs") managed by Private Corner;
- constitute an offer or solicitation to sell shares or units of any of the AIFs referenced on this site, to anyone in any jurisdiction where such an offer, solicitation, or distribution would be deemed illegal or where the person responsible for such offer or solicitation is not authorized to do so, or to any person to whom such offer or solicitation is prohibited.
Numerous restrictions and eligibility conditions, regulatory or statutory, not described or only briefly mentioned on this site, govern the subscription or acquisition of shares or units in these AIFs, their presentation and distribution methods by intermediaries (depending in particular on the investor's place of residence), eligibility conditions related to the investor (based in particular on their financial knowledge, financial resources, regulated or non-regulated status, variable categorization from one country to another), or the minimum investment amount required by the AIF's documentation.
In general, the AIFs managed by Private Corner are only intended for professional or equivalent investors.
The risks, fees, commissions, and recommended investment horizons for the presented AIFs are detailed in the prospectus/rules of the AIFs, which are made available to the investor before any subscription.
This official documentation is only available from Private Corner or third-party partners expressly authorized or mandated by Private Corner, sometimes exclusively in a given territory and/or a defined investor segment.
The value of your investments in these AIFs and the potential income derived from them may fluctuate, both upward and downward, and are in no way guaranteed. The risk of capital loss is equivalent to the amount invested.
As a professional or equivalent investor, it is your responsibility to know and comply with all applicable legal and regulatory provisions in the relevant territory.
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Private Corner is an independent asset management company providing private banking professionals with investment solutions in unlisted assets on behalf of their individual clients. To find out more about our comprehensive range of investment funds (private equity, co-investment, private debt and infrastructure), please contact us.
[The “apport-cession” scheme (https://private-corner.eu/newsroom/guides/apport-cession-150-0-b-ter) is a tax mechanism that enables a company director or investor to defer taxation on the capital gain realized when he or she transfers shares in his or her company to a holding company. In concrete terms, instead of selling his shares directly and being immediately taxed on the capital gain, the entrepreneur first transfers them to a holding company he controls. This operation temporarily “blocks” taxation, provided that the holding company retains the shares for a certain period and reinvests the proceeds of their resale according to precise rules.
This mechanism is designed to facilitate asset reorganization or business transfers, without creating an immediate tax brake. It is particularly useful for :
Prepare the sale of a company under the right conditions,
Reinvest the proceeds in the real economy,
Organize the holding of shares via a holding company,
Optimize taxation with a view to patrimony or inheritance.
The contribution-asset scheme is based on two main stages.
First, the executive contributes the shares in his company (for example, a small business he has set up) to a holding company he controls. This contribution normally triggers a capital gain, but thanks to the scheme, its taxation is deferred: it is not cancelled, but deferred.
The holding company may then decide to sell the shares. If this sale takes place quickly (within three years), then to maintain the tax deferral, the holding company must reinvest at least 60% of the proceeds of the sale in eligible economic activities such as SMEs, or a private equity fund (FPCI), for example. If this condition is met, the tax is deferred. On the other hand, if the reinvestment does not take place on time, or if the entrepreneur subsequently sells the holding company's shares, the deferral ends and the tax becomes due.
For reinvestment of the proceeds of sale in an FPCI (Fonds Professionnel de Capital Investissement) is eligible for continued tax deferral under the capital transfer scheme (article 150-0 B ter of the CGI), several strict conditions must be met:
Reinvestment deadline The reinvestment must be made within two years of the sale of the shares transferred to the holding company.
Amount reinvested At least 60% of the sale proceeds (net of expenses) must be reinvested in an eligible economic activity.
Nature of the FPCI The FPCI must meet the following eligibility criteria:
It must be approved by the AMF or managed by an approved management company.
It must invest mainly in operational, unlisted companies (SMEs or ETIs) engaged in commercial, craft, agricultural, industrial or professional activities.
It must meet an investment quota in unlisted securities (generally at least 50%), in companies headquartered in a member state of the European Union or the European Economic Area.
Arm's length FPCIs must not invest in companies affiliated with the contributor or the holding company, in order to avoid any abusive reintegration into their own economic group.
Holding period The reinvestment must be held for at least 5 years, except in exceptional cases provided for by law (notably if the FPCI redistributes its assets in accordance with regulations).
These conditions are governed by the tax authorities: any breach can result in the tax deferral being called into question, with retroactive effect. It is therefore essential to enlist the help of professionals to ensure the security of the asset transfer arrangement.
If you have any questions about this scheme, codified in article 150-0 B ter of the CGI, please do not hesitate to contact us:
Private Corner AMF approval GP-20000038 161 rue du Faubourg Saint-Honoré, 75008 Paris +33 (0)1 83 75 66 93 contact@private-corner.eu