Decree 2006-1309 of 25 October 2006 on the application of the new CFC legislation set out in Art. 209B of the French Tax Code (CGI) was published in the Official Journal No. 250 of 27 October 2006. The Decree replaces Art. 102 SA to Art. 102 Z of Annex II of the CGI by Art. 102 SA to 102 ZB. Note that the tax administration released a draft Guideline commenting on the new provisions. The mos…