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In this issue:

International Taxation

  • Latest developments in the General Electric Medical Systems case: burden of proof in transfer pricing matters and consequences on the value added for business tax purposes
  • Modalities for implementing the general principle of EU law prohibiting abusive and fraudulent practices

Corporate Tax

  • Limitation to the transfer of the overall group tax losses in case of absorption of the head company
  • Sale at a discounted price of equity securities - exclusion from long-term capital gains special regime
  • Sale of shares at a reduced price between related parties and appreciation of the significant difference of price
  • The election for offsetting long-term net capital gains with operating losses is final and binding on the taxpayer, including in the event of a subsequent cancellation of said losses by the tax administration


  • Acknowledgement of an abuse of law by the abuse of doctrine?
  • A decision of the French Constitutional Court is not in itself an event that may open a new time limit for complaint

Individual Taxation

  • Withholding of income tax: review of some practical issues
  • The bonus paid by a sport federation to a professional player provided by the club that employs him is a salary
  • Management packages : criteria in tax matter keep being clarified

Real Estate Taxation

  • Real estate dealers: Be careful with the cost of carrying the VAT on acquisition!
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