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 clarifies tax treaty suspension with Russia
The French General Directorate of Public Finances published a guidance, on 23 October 2024, for the application of the France and Russia income tax treaty following the suspension of several provisions of the agreement. Despite the suspension,
Read MoreFrance proposes digital services tax rate increase
France’s National Assembly members have proposed on 17 October 2024 to increase the digital services tax rate from the current 3% to 5% in the Finance Bill 2025. The proposed digital services tax rate increase is expected to generate EUR 500
Read MoreFrance: Finance Committee approves amendment on tax residency for citizens residing abroad
The Finance Committee of the French National Assembly has approved an amendment to the 2025 Finance Bill that changes tax residency rules for individuals. This amendment introduces a "targeted universal tax" mechanism for French citizens who move
Read MoreFrance activates MFN clause in tax treaty with Latvia
The French tax authority issued a notice on 16 October 2014, regarding the implementation of the most favoured nation (MFN) clause in the 1997 tax treaty with Latvia. This convention, signed in Paris on 14 April 1997, includes a most-favoured
Read MoreFrance to facilitate extensive adoption of electronic invoicing
The French government has announced plans to facilitate the extensive adoption of electronic invoicing on 15 October 2024. The initiative is expected to improve payment timelines and streamline invoicing processes while simplifying interactions with
Read MoreFrance sets new interest rates for shareholder interest deductibility
France has published interest rates for entities whose financial year (FY) ended between 30 September and 30 December 2024, which are used to determine the deductibility of interest payments to shareholders. The applicable rates from 30 September
Read More