July 29, 2021

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Temporary neutralization of free asset revaluations: details



Companies may, under certain conditions, replace the historical value of assets on their balance sheet with their real value in order to give a more accurate picture of their assets. The objective of this free revaluation being to strengthen their own funds in order to be able to access financing more easily.

Namely: the revaluation must relate to all the tangible and financial fixed assets of the company (buildings, furniture, equipment, vehicles, equity securities, etc.). Intangible assets (business assets, software, patents, licenses, etc.) are not concerned.

Normally, the capital gains resulting from this operation constitute taxable income for the year during which the revaluation was carried out. However, on a temporary basis, the imposition of this revaluation surplus may, optionally, be deferred. A system which is applicable to the first revaluation operation carried out at the end of a financial year ending between December 31, 2020 and December 31, 2022.

As such, the tax administration specifies, in particular, that this regime concerns companies subject to the rules of commercial accounting, excluding those imposed in the category of non-commercial profits (BNC).

Concretely, the capital gain can be spread out or placed on a tax suspension depending on the depreciable nature or not of the revalued fixed assets. On condition, with regard to non-depreciable fixed assets (brands, land, equity securities, etc.), that the company undertakes to calculate the capital gains or losses realized during the subsequent disposal of the assets according to their non-depreciable value. revalued, that is to say, specifies the administration, according to their tax value before revaluation.

Example: a company acquires a non-depreciable fixed asset for 100,000 € in year N. It proceeds in year N + 2 to an overall revaluation of its tangible and financial fixed assets, at the end of which the value of this fixed asset is estimated to 150,000 €. In N + 4, it sells this fixed asset for € 175,000. The revaluation surplus recorded in N + 2, the taxation of which has been suspended, is € 50,000 (150,000 – 100,000). But the capital gain on taxable disposal in N + 4 is € 75,000 (175,000 – 100,000).

Remember that the capital gain on depreciable assets is spread over a period of 15 years for buildings and 5 years for other fixed assets.

Note: a follow-up statement containing the elements useful for calculating depreciation, provisions and capital gains or losses relating to revalued fixed assets must be attached to the income statement for the year during which the revaluation was carried out and of the following exercises.

BOI-BIC-PVMV-40-10-60-30 of June 9, 2021