Draft legislation introducing a presumption that profits are received if functions and risks are transferred to a foreign related party, unless arm’s length remuneration is paid, has been struck down by the Supreme Court and will not be implemented in its current form.
Â
Related Posts
France has approved a special budget bill on 11 December 2024, allowing the State to collect taxes and borrow funds necessary for financing essential public expenditure until the 2025 Finance and Social Security Finance Laws are implemented. This
Read More France has issued Decree No. 2024-1126 on 4 December 2024 in the Official Gazette, which sets out the regulations for implementing the Pillar Two global minimum tax (GloBE) rules as part of the Finance Law for 2024 (Law No. 2023-1322 of 29 December
Read More
French Prime Minister Michel Barnier announced on Thursday, 28 November 2024, that he will be abandoning plans to raise electricity taxes in his 2025 budget, responding to threats from the far-right National Rally (RN). Barnier had aimed to raise
Read More
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 More
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 More 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 More
