French multinational aerospace and defence corporation Safran has received approval to re-domesticate its Luxembourg captive to France.
Safran’s new French captive, Soreval France, will have the authority from the French regulator to write non-life risk.
The number of captives in France has gradually increased since the jurisdiction introduced specific captive legislation in June 2023, with the number of captives in France now standing at 19.
French-owned captives have typically gravitated towards Luxembourg and Ireland, while there are also French captives in Malta, Switzerland and Guernsey.
Captive Intelligence understands that there could be up to 10 more companies waiting for approval from the French regulator to form a captive in the jurisdiction.
Those close to the French captive regime have previously told Captive Intelligence that they do not expect there to be many re-domestications to France, primarily due to tax and administrative reasons.
France still outsources a lot of its captive services to Luxembourg, but there is a drive to enhance the county’s captive eco-system, with firms such as SRS launching offices in the jurisdiction.
The most notable feature of France’s captive legislation is its equalisation provision, which largely resembles the provision offered in Luxembourg, although not quite as generous.
François Messner, Senior Manager at EY Luxembourg, Business Tax Advisory and Hicham Mazouz, Partner at EY Luxembourg, Audit, financial Services, examined the differences between the French and Luxembourg captive regulatory environments and their respective equalisation provisions.