The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax treatment of interest deductions taken by a French company on interest payments to a related Belgian company that benefits from the Belgian notional interest rate scheme. In accordance with the French Law, interest on total amounts paid to an affiliate enterprise outside France is only deductible if a minimum rate of tax applies to the relevant income abroad.
World Tax Brief: September 2019
Related Posts
France issues guidance on treaty-based dividend withholding relief
France’s tax authority has issued guidance clarifying its taxation methods for dividends and similar income under international tax treaties, particularly focusing on treaty benefits for distributions to residents of countries with specific
Read MoreIndia, France sign amending protocol to tax treaty
India’s Central Board of Direct Taxes issued a press release on 23 February 2026, announcing that an amending protocol to the 1992 France–India income and capital tax treaty was signed on 17 February 2026. The protocol introduces significant
Read MoreEU Commission presses France to end restriction breaching parent-subsidiary rules
The European Commission sent a letter of formal notice to France for applying national criteria to determine whether a parent company qualifies for a withholding tax exemption on subsidiary distributions, in its March 2026 infringements package. The
Read MoreFrance updates 2026 rent, tenant income ceilings for property investment incentives
France’s tax authorities have released the 2026 rent and tenant income ceilings for rental property investment schemes on 10 March 2026. From 1 January 2026, properties must be rented within the set ceilings, and tenants’ incomes must meet
Read MoreFrance clarifies VAT rules for dropshipping without IOSS registration
France’s tax authorities have issued guidance on value-added tax (VAT) for dropshipping transactions where merchants sell goods online to consumers in France or other EU Member States without holding inventory and have not opted into the VAT
Read MoreFrance nears completion of tax treaty negotiations with Cambodia
France began negotiations with Cambodia at the end of 2023 for an income tax treaty. The talks are now “about to be completed,” according to a response published on 5 February 2026. The treaty will prevent double taxation for residents
Read More