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