In a Ministerial Reply published on 22 January 2013 (Réponse Ministérielle Urvoas du 22 Janvier 2013, question écrite n° 13146 de monsieur Jean-Jacques Urvoas), the tax administration confirmed that the capital value of a life annuity (rente viagère) remains subject to net wealth tax.

Under article 885 E of the French Tax Code, the tax base of the net wealth tax is calculated on the net value, as at 1 January of the tax year, of all property, rights and taxable valuables belonging to the taxpayer.

The Government has confirmed its position. Therefore, the capital value of a life annuity remains subject to the net wealth tax.

The Government justifies its position under the principle of equality before tax.

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