Contribution-sale: a technical mechanism at the heart of wealth management and entrepreneurial strategies
Serge CAMBIE and Thibault PILA , associate lawyers at the law firm BREMENS AVOCATS, had the pleasure of hosting, on April 21, 2026, at the Cercle de l’Union premises , alongside KMH and ANGELOR , a conference dedicated to the contribution-sale mechanism , an incentive and technical device, at the crossroads of tax law, company law and asset structuring.
We warmly thank Guillaume HUBLOT and Sébastien BONTE for the quality of their contributions and this demanding collaboration, as well as LYON PLACE FINANCIÈRE , and especially Carine POTTIN-GORBATOFF and Frédéric MIRIBEL , for their support in the organization of this event.
The aim of this presentation was to highlight:
- the key structural elements of the contribution-sale regime,
- Recent legislative developments concerning Article 150-OB ter of the French General Tax Code (CGI), in particular the 2026 Finance Law which has tightened the conditions for applying said provision ,
- and above all, the contributions of tax case law , which have become decisive in securing transactions.
More than ever, the implementation of the contribution-sale requires a rigorous, anticipated and multidisciplinary approach , adapted to the profile of the manager and shareholders, the economic reality of the operation and the objectives pursued.
BREMENS AVOCATS supports its clients at every stage of the planning and implementation of these complex schemes , combining technical expertise, strategic vision and a deep understanding of the asset and business challenges.
The full report is available here: https://communications.kmh.fr/focus-sur-le-mecanisme-de-l-apport-cession
