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How is this type of financing treated for tax purposes?

The tax treatment depends on the structure chosen. Where the financing takes the form of a purchase followed by a firm-price resale, the funder's margin is a commercial profit taxable in its hands, and the price paid by the company is treated as the acquisition cost of an asset, depreciable under ordinary rules.

Where the financing takes the form of an equity contribution, the capital provider's return is a distribution of profit, subject to the regime for revenus de capitaux mobiliers (investment income) or to the corporate regime, as the case may be.

In every case, the contractual documentation must faithfully reflect the real economic operation. It is that consistency that lets the arrangement stand up in a tax audit.

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