Since 2007, France has offered a tax-exempt collective investment fund vehicle for real estate that is suited to long-term investments. This vehicle is called an OPCI or Organisme de Placement Collectif Immobilier. OPCIs are a form of alternative investment fund regulated by the AIFM Directive (Directive 2011/61/EU of 8 June 2011).
OPCIs are flexible schemes that allow “club deals” or groups of professional investors to invest through structures that facilitate rental property investments. OPCIs are also secured vehicles that are regulated by the French market authorities (Autorité des Marchés Financiers (AMF)), since they must be approved by the AMF prior to their constitution.
From a French tax standpoint, OPCIs are attractive vehicles. OPCIs are exempt from corporate income tax on all income (subject to satisfying distribution requirements, see below). Income is distributed in the form of dividends, which are taxed at shareholder level.