Salans Paris has advised Ingepar (a subsidiary of the Caisse d'Epargne Group) with respect to a tax driven financing under articles 217 undecies and 217 duodecies of the French General Tax Code, for the acquisition of 78 residential housing units in French Polynesia by SCI Jardins de Paea (a French civil partnership which shareholders are, inter alia, a subsidiary of an international group as tax driven investor and SAEM SAGEP, a company held mainly by French Polynesia).
The acquisition price of approximately Euro 20,000,000 was financed by (i) a term loan facility granted by Financière Océor (another subsidiary of the Caisse d'Epargne Group), (ii) an increase of SCI Jardins de Paea's share capital entirely subscribed by the tax driven investor and (iii) a subordinated interest-free loan granted by the seller (which is also a shareholder of SCI Jardins de Paea).
The residential housing units shall be managed by SAEM SAGEP and rented to people meeting specific criteria with respect to their revenues for at least a 6-year period and for rents inferior to caps determined by French domestic and Polynesian tax law. As of the end of the rent period, the lessees shall be entitled to acquire the residential housing units.
The transaction was led by Banking & Finance partner Philippe Max, by Tax Law counsel Charles-Henri de Saint Julien, by Corporate Law partner Thierry Renaud de la Faverie and by Real Estate Law counsel Antoine Mercier, with the assistance of Banking & Finance associate Maria Nenova and Corporate Law associates Caroline Bortolaso and Cécile Szymanski. François Froment-Meurice, client relationship partner, supervised the transaction.
Contacts
Paola Pozzi-Dazza, Marketing & Communication Manager
Tel: +33 1 42 68 92 72 - Fax: +33 1 42 68 70 60
E-mail: ppozzi@salans.com