113 results found

The research tax credit claim is immediately repayable when it is established by a company that has been the subject of a conciliation or safeguard procedure, a reorganisation or a judicial liquidation...

The FTA had denied the Exemption on the basis of the so-called "abuse of law" procedure, i.e., that the Sub had no other purpose than to "transform" taxable income into quasi tax-exempt dividends.

In 2000, the head of the French tax grouping (Parent) sold to its subsidiary in charge of financial matters and inactive participations (FinCo) the shares of an inactive subsidiary (Sub).

In a nutshell, where the market value of such shares at the time of their issuance is lower than their book value, the difference may not be deducted from the taxable profits of the taxpayer at the time of the sale.

The European Union's fragmented approach to Real Estate Investment Trust (REIT) taxation creates significant cross-border challenges, with structures potentially facing up to three layers of taxation despite domestic...

A French bank, acting from its head office, had advanced loans to various branches located in China, Philippines, India, Singapore, and Thailand.

François Vignalou est intervenu pour l'article « L'exonération du régime mère-fille dépasse le seul cadre de l'impôt sur les sociétés » pour L'AGEFI.

As discussed in previous French Tax Updates, the treatment of French source dividends paid to foreign nonprofit organizations (NPOs) raises the issue of comparability of NPOs with French nonprofit organizations.

Considering that such provisions had never been reviewed by the Conseil constitutionnel and could potentially create a breach of equality between taxpayers, the Conseil d'Etat requested a QPC from the Conseil constitutionnel.

The French tax authorities challenged, under the abuse of law doctrine, the tax deduction of the interest payments made by FCo, on the grounds that the issuance of the ORAs was purely tax motivated.

French Tax Update is a periodic publication that examines the French hot topics in the field of tax.

The French Supreme Court has clarified how to interpret the concept of a legal entity whose assets consist principally of immovable property when this concept is not defined in an applicable tax treaty. The decision addresses whether interests held by family members and indirect holdings through intermediary entities must be considered when determining if a company falls within the scope of real estate provisions in tax treaties.

Further to the introduction of thin-capitalization rules in 2007, which limited the deduction of interest accruing on intragroup debt financing and the enlargement of their scope in 2011 to third-party debt secured by guarantees provided by an affiliate, France has just introduced another limitation of the deductibility of interest expenses for holding companies.

The CJEU confirmed on 17 May 2017 that the French 3% tax on distributed earnings is contrary to the Parent-Subsidiary Directive.

Article 1736 IV bis of the French Tax Code (FTC) imposes very high penalties for trustees who fail to comply with filing requirements imposed by French tax legislation applicable to trusts.

La loi de finances pour 2023 apporte plusieurs modifications au statut des JEI: