A ministerial reply (Mazeaud, AN April 22, 1996, p. 2201, no.34229) sets out the VAT regime applicable to commissions earned by intermediaries whose activity consists in transmitting financing requests to lease-purchase companies. The administration considers that leasing and lease-purchase operations must be analyzed, up until the date of the exercise of the option to purchase, as rentals of property. These operations are therefore not covered by the provisions of Article 261 C 1 of the French Tax Code, which provide for a VAT exemption for banking and financial operations. Consequently, for the administration, the services provided by an intermediary in the realization of lease-purchase operations may not be exempted from VAT, pursuant to Article 261 C 1 of the French Tax Code, even though the intermediaries who realize such operations are subject to the banking law of January 24, 1984.

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