News

Compensation tax and mixed-activity parent companies: hopes are up

A State Council ruling on February 14th 2018 (State Council 8e-3rd chamber, February 14 2018, N°410302, Nord Provence Finances) restated the rule that dividends received by a company, including a parent company with a role in managing subsidies (especially services subject to VAT for these companies), must be included in the compensation tax liability report […]

Tax alert

Is tax integration falling apart as a system?

Report in Les Echos Executives, February 26th 2018

News

Arsene advises Idinvest Partners in its investment in Vision Systems

Idinvest Partners, advised by Arsene and others, bought into the capital of Vision Systems, a medium-sized business of the Lyon area and world leader in solar protection systems, with a 20% stake, following in the steps of A Plus Finance that supported the group from 2013 up until now. This transaction is rounded off with […]

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Arsene advises Casino Group in the acquisition of Sarenza

Arsene advised Monoprix, a subsidiary of Casino Group, as it announced the start of negotiations to acquire Sarenza. Following recent partnerships signed by the retailer, with Ocado and others, this acquisition aims at adding to Monoprix’s current offer and positioning it as an omni-channel Lifestyle retailer (Fashion, Home, Beauty). This acquisition is fully in line […]

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Priority Preliminary Ruling on the Issue of Constitutionality – The “Charasse Amendment” or irrefutable presumption of fraud?

The State Council’s decision (State Council, February 1 2018, N°412155) to refer a priority preliminary ruling on the issue of constitutionality on the Charasse amendment to the Constitutional Court will not solve problems related to defining joint control. Option Finance N°1450, February 19th 2018    

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Share of costs and expenses on dividends from non-European subsidiaries: a priority preliminary ruling on the issue of constitutionality

The State Council issued a ruling on January 24th 2018 (N°415726, Lige Sciences Finances Holding France) transferring a priority preliminary ruling on the issue of constitutionality to the Constitutional Council pertaining to the application of a 5% share of costs and expenses (QPFC) to dividends received from non-European subsidiaries. The ruling pertains to the timeframe […]

Tax alert

The national financial prosecutor is set on getting rid of Bercy’s fraud prosecution monopoly

The national financial prosecutor’s office has announced that it earned nearly 800 million euros for the state last year. It now hopes to extend its powers by getting rid of Bercy’s monopoly on fraud prosecution. Option Finance N°1447, January 29th 2018

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Winter real estate conference 2018, les lignes bougent !

Le cabinet ARSENE a le plaisir de vous inviter à sa Winter Real Estate Conference 2018, qui se tiendra de 8h15 à 10h le 7 mars prochain au Royal Monceau. L’équipe immobilier du cabinet Arsene vous accueillera au cours d’un petit-déjeuner conférence pour vous présenter l’actualité fiscale immobilière de ce début d’année. 1.    Programme Loi […]

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A review of the substantial tax system modifications pertaining to corporate tax restructuring

Following the Euro Park Service rulings (EUJC, March 8 2017, aff. C-14/16 and State Council, June 26 2017, N°369311), lawmakers were required to put an end to the discrimination created by differential treatment of contributions between two French companies that fulfilled merger control conditions, were not subject to preliminary agreements, and contributions made by a […]

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The authorities have their sights set on VAT

France as well as the European Union have realised that they could collect additional VAT by tackling fraud. How this tax actually works, a topic at the heart of several judicial and political decisions, is hard to reform. Option Finance, N°1445, January 15th 2018

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Verifying constitutionality of EOY finance laws

The French Constitutional Council issued two rulings on December 28 2017: one on the 2018 Finance Law and the other on the 2017 amending law. Excluding non-financial provisions in financial acts, the Constitutional Council issued limited censure. On Cons. const. 28-12-2017 N°2017-758 DC and N°2017-759 DC. Feuillet Rapide N°3 / Quick Look N°3 / January […]