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International Taxation

Some news about the Multilateral BEPS Convention

Useful clarifications provided by the French Supreme Administrative Court on whether government subsidies could be deducted from the cost base without leading to an indirect transfer of profits

France-United Kingdom tax treaty: factors characterizing the existence of a fixed place of business in France and proof of the absence of hidden activity within this permanent establishment

Corporate Taxation

A company may offset losses made during the financial year in which it carried out a mixed commercial and financial activity against the profit generated in the following financial year despite the termination of its commercial activity

Exemption from withholding tax: notion of place of effective management

Non deductibility of provisions related to staff and structural costs for disputes arising out of the ten-year guarantee

Justification of the interest rate paid to affiliated companies - an impossible proof?

Litigation

Confirmation of the interpretative reservations regarding the cumulative application of tax and criminal penalties

The capital gain used to calculate the Business Added Value Contribution base has to be determined by taking into account the net book value

Real Estate Taxation

The free revaluation of the assets of a SCI held by private individuals has no tax consequences

Individuals Taxation

No tax residence in France without a personal dwelling!

Wealth tax: for the valuation of the shares of a non-resident shareholder in a predominantly real estate company, shareholder debts towards other non-resident shareholders are deductible

Professional assets of an independent business: notion of professional utility

VAT

Head office and Branch: the case is in the hand of the ECJ

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