Paris Tax Newsletter
- Brussels: between the carrot and the stick
- The Nantes administrative court of appeal sheds new light on the attribution of the burden of proof in transfer pricing matters and assignment of affiliated company liabilities
- The reversal of an impairment which was not tax deductible at the time of its booking must not lead to taxable item!
- Splitting of shares: tax neutrality for shareholders subject to corporate income tax
- In case of merger, a mixed-activity holding company cannot transfer, by tax ruling approval, the losses deriving from the acquisition and holding of shares
- A share buy-back followed by a share capital decrease may constitute an abnormal management act disallowing the deduction of interest on the loans that financed the transaction
- The French tax administration allows the splitting of the income distributed by SICAVs to their foreign unit holders
Territorial Economic Contribution
- Specific relief for territorial economic contribution (CET): do not merge the eligible companies before 2013!
- Tax consolidation: impossibility of taking into account tax losses generated by European subsidiaries is deemed in conformity with the freedom of establishment principle even when there are losses that may no longer be taken into account in the Member State of the subsidiaries
- Tax procedure: international conventions and secrecy of information collected by the tax administration in the framework of international assistance
- Draft guideline on the tax credit for optional profit sharing "intéressement" or how the tax administration accepts the principle of not withdrawing a favorable measure previously granted...
- Wealth Tax: Partners in Real Estate Investment partnerships ("SCIs") with a predominantly commercial activity are eligible for exemption on financial investments made by non residents
- Publication of EU Regulation