ASSURANCE VIE1
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9 mars 2016
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31 mars 2016

LES CONTRATS D’ASSURANCE VIE N’ÉCHAPPENT PAS A L’ISF

ASSURANCE VIE3

Sans remettre en cause l’économie générale de l’assurance vie. le fisc cerne de plus en plus précisément les contours de son cadre fiscal et des avantages qu’il procure. Le particulier aventureux qui cherche a trop étendre le champ de l’assurance vie risque gros. Dans cette joute, il tient le rôle du pot de terre, comme l’illustre la décision qui suit.

De leur belle demeure des bords de l’Adour, Edouard et Marie-Christine administrent avec habilité un patrimoine que l’on peut qualifier d’important.

A la fin des années 80, Edouard entre en assurance vie. Son contrat prévoit le versement d’un capital de 30 millions de francs (augmenté d’un intérêt de 6,50 % par an, plus une participation aux bénéfices) en faveur de son épouse s’il décode. S’il est vivant au terme du contrat, il recevra au minimum 56.34 millions de francs. Edouard peut bien entendu, s’il en éprouve le besoin, opérer des retraits anticipés. Mais il décide – et le fait constater contractuellement – de s’interdire toute faculté de rachat avant le 1*’ avril 1995. Pour quelle raison ? Pour, du moins le pense-t-il, faire « sortir » cet actif de son patrimoine et donc de sa base taxable à l’ISF.

Hélas ! après un contrôle, le fisc lui notifie un avis de mise en recouvrement assez salé, basé sur la réintégration de la valeur de rachat du contrat. Edouard et Marie-Christine portent l’affaire devant les tribunaux. Ils n’obtiennent que très partiellement satisfaction (« seul » le montant de la prime versée est réintégré dans la base taxable à chaque 1er janvier) et en appellent à la Cour de cassation. La Direction Générale des Impôts fera de même, de son côté, pour élargir l’assiette taxable aux valeurs de rachat. Le verdict des juges est net. En premier lieu, ils rappellent que le droit de rachat n’est pas « simplement virtuel » et que. « même différé, [il] a une valeur économique ». Conséquence : le contrat est un élément de patrimoine. La demande du fisc est favorablement accueillie, à partir d’un argument technique (la rédaction de l’article 885F du Code Général des Impôts ayant été modifiée a dater du 1′ » janvier 1992).

L’assurance vie n’est pas plus faite pour contourner les régies de la succession que pour faire échapper un plan de patrimoine à l’ISF. Explorer cette voie vous expose à de sévères déconvenues. Pour vous ou pour vos héritiers.

 

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