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 delays VAT code migration to CIBS until 2027
France has postponed the transfer of Value Added Tax (VAT) provisions from the General Tax Code (CGI) to the Code des impositions sur les biens et services (CIBS) until 1 January 2027 under Ordinance No. 2026-671 of 27 July 2026, published in the
Read MoreArgentina ratifies second amending protocol to income tax treaty with France
Argentina has gazetted Law 27814 on 17 July 2026, which ratifies the amending protocol to its 1979 income and capital tax treaty with France. Signed on 6 December 2019, the protocol is the second to amend the treaty. It will enter into force 30
Read MoreFrance confirms mandatory e-invoicing rollout from September 2026
The French Ministry of Economy and Finance has announced the forthcoming implementation of mandatory electronic invoicing (e-invoicing) requirements in Communication No. 898 issued on 11 July 2026. From 1 September 2026, all businesses must be
Read MoreCanada, France sign competent authority arrangement on MLI arbitration procedures under tax treaty
According to a recent update from the Canadian government, Canada and France have signed a Competent Authority Arrangement establishing the procedures for applying the arbitration provisions under Part VI (Arbitration) of the OECD Multilateral
Read MoreFrance issues rules for preparing, filing CbC reporting
France has published the Order of 3 July 2026 in the Official Gazette on 9 July 2026, establishing the rules for preparing and filing the profit tax information declaration (Public Country-by-Country Report) required under the French Commercial
Read MoreFrance extends GIR filing deadline
France’s Ministry of Economy and Finance announced an extension of the filing deadline for the GloBE Information Return (GIR) for the financial year ended 31 December 2024 through a press release issued on 8 July 2026. The deadline, which was
Read More