Changes to the deductibility of interests exprenses – Legislative initiatives (Kreditzweitmarktförderungsgesetz et Wachstumschancengesetz) Link to the publication: https://www.editions-jfa.com/category/revue-fi-1-fevrier-2024/
Organization of the 2023 edition of our « International Taxand Tour » event at the Hotel Lutetia in Paris on the current international tax landscape. Topics covered included permanent establishment, beneficial ownership, anti-abuse measures and international tax audits. During this meeting, the debates were moderated – in French and in English – by a panel of […]
Participation in the panel discussion on recent decisions in international tax law („Aktuelle Entscheidungen zum Internationalen Steuerrecht“) For more information on the content of the seminar and the participants : https://www.ists.ch/tagung-2023/
Participation at the 2022 edition of our « International Taxand Tour » event at Dusseldorf and Frankfurt on the current international tax landscape. Topics covered included the global mobility tax challenges, taxation of management packages and French-German TP rules on cash pooling. The debates were moderated – in English – by a panel of partners from […]
Organization of the 2022 edition of our « International Taxand Tour » event at the Hotel Lutetia in Paris on the current international tax landscape. Topics covered included the current international tax landscape, in the light of recent geopolitical and economic upheavals. The debates were moderated – in English – by a panel of partners from […]
Participation in the panel discussion on recent decisions in international tax law („Aktuelle Entscheidungen zum Internationalen Steuerrecht“) For more information on the content of the seminar and the participants : https://www.ists.ch/tagung-2022/
Participation in the panel discussion on recent decisions in international tax law („Aktuelle Entscheidungen zum Internationalen Steuerrecht“) For more information on the content of the seminar and the participants : https://www.ists.ch/tagung-2022/
Since 19 July 2019, mergers between sister companies wholly owned by the same entity have to be carried out without any exchange of shares by the common shareholder (Law no. 2019-744 of 19 July 2019 on the simplification of company law codified in Article L.236-3 of the French Commercial Code). The associated rules on the […]
In a judgment of 29 May 2019 (CE 3rd-8th ch. 29 May 2019, No. 411209, Montisambert), the French Council of State (“Conseil d’Etat”) confirmed that securities may qualify as participating interests, resulting in the near-total exemption from corporate tax of the capital gain accruing on their disposal, to the extent that the acquiring company intended, […]
Transposing Article 6 of the ATAD Directive, Article 205 A of the French General Tax Code provides for a new general anti-abuse rule for corporation tax, under which no account is taken, while assessing the amount of a corporation tax liability, of the tax consequences of an arrangement or a series of arrangements: the main […]
In an opinion handed down on 10 July 2019, the Conseil d’Etat helpfully clarified that interest rates used on intra-group loans may be justified through the of bond benchmarking, where no evidence of loans granted by financial institutions was available. Background: If a taxpayer wishes to apply a higher interest rate than the reference rate […]
On Thursday 14 March 2019, the Minister of the Budget revealed a set of immediately effective initiatives that may radically overhaul relationships between companies and the tax authorities. Time will tell whether the revolution will indeed take place, but the introduction of several initiatives should cause companies to take stock and determine which initiatives they […]