France-ruling on 75% withholding tax on dividends paid to residents of NCSTs in accordance with constitution
The Constitutional Court of France delivered its decision (No. 2016-598 QPC, Eurofrance) on 25 November 2016 about the compatibility with the constitution of the 75% withholding tax rate applicable to dividends paid to a resident of a
See MoreFrance-amending Finance Bill for 2016
The Amending Finance Bill for 2016 (projet de loi de finances rectificative pour 2016, PLFR) (the Bill) was presented by the government and submitted to the National Assembly on 18 November 2016. The Ministry of Finance of France announced to
See MoreFrance-New threshold for eligibility of abridged transfer pricing documentation
In France, a new law had been enacted on 8 November 2016 which provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257). The threshold as codified at Article 223 quinquies
See MoreFrance-Finance Bill for 2017
The government of France presented the Finance Bill for 2017 on 28 September 2016. According to article 6 of the Bill the standard corporate income tax rate, currently set at 33.33%, will be reduced progressively to 28%. However, the 28% rate will
See MoreFrance: Announces draft Finance Bill for 2017
The French Ministry of Finance presented, during a press conference on 28 September 2016, the main tax provisions of what will be the draft Finance Bill for 2017, prior to the bill being submitted to the French Parliament. Among the provisions that
See MoreFrance-announcement of decrease in income tax rates in 2017 Budget
The government of France announced that the current corporate income tax rate of 33.33% will be reduced in the 2017 fiscal Budget. Starting from 2017, a lower rate of 28% will be applicable to small and medium-sized enterprises (SMEs) for profits
See MoreIMF comments on the economic and fiscal position of France
On 24 May 2016 the IMF published a report on its website following the conclusion of consultations with France under Article IV of its articles of agreement. The IMF notes in the report that France’s economy is recovering but major efforts are
See MoreFrance-public consultation launched on 1% add-back on dividends within tax-consolidated groups
The Tax Administration of France published on 11 May 2016 guidelines on the taxation of dividends distributed within tax-consolidated groups following changes brought by the Amending Finance Law 2015. For financial years commencing on or after 1
See MoreFrance- amortization base of 140% further extended by 1 year
The French Ministry of Finance and Public Accounts has declared that the tax measure letting companies to use an amortization base of 140% on certain industrial investments will be further extended by 1 year. Accordingly for investments in
See MoreFive European countries to exchange information on beneficial ownership
On 15 April 2016 it was announced that Britain, France, Germany, Italy and Spain have agreed to exchange information on beneficial ownership of companies and of "trusts with tax consequences". The five European countries will explore the best way to
See MoreFrance-New country-by-country reporting requirement, transfer pricing declaration
The Finance Act for 2016 and the Amended Finance Act for 2015 were published in the official journal on 30 December 2015. The Finance Act for 2016 introduces a country-by-country reporting obligation in Article 223 C of the French general tax code,
See MoreFrance-New tax and social security changes including mandatory e-filing of tax returns
The French Social Security Financial and Income Tax Bills of 2016 will bring changes to the countries income tax and social security rates and bands. Additionally, e-filing of returns will be mandatory for any individual earning in excess of EUR
See MoreFrance: Abolition of add-back on dividends within tax-consolidated groups
An amendment was adopted by the National Assembly on 2 December 2015 to abolish the neutralization within tax consolidated groups of the 5% add-back on dividends qualifying for the participation exemption. The add-back will therefore be reduced to
See MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
See MoreFrance adopts country-by-country reporting requirement
The lower house of the parliament in France adopted an amendment to the Finance Bill for 2016 on 12 November 2015. The amended Finance Bill introduces a country-by-country reporting requirement for multinational companies which will be applicable
See MoreFrance: Draft Finance Bill 2016
The draft Finance Bill for 2016 has been presented in France. According to the proposals the income tax-exempt threshold will be increased to EUR9,700 (USD10,840). For income above this threshold the income tax rates will be reduced. The tax rates
See MoreFrance: New article on transfer pricing assessments and withholding tax relief for repatriated profits
A new Article L. 62 A of the French tax procedure code was published in the official bulletin on 2 September 2015. The article provided rules that efficiently establish the tax treatment of certain profits transferred abroad by French taxpayers, and
See MoreFrance introduces withholding tax on benefits from employment
On 17 June 2015, the Ministries of Finances and Budget declared that a withholding tax system for fringe benefits will be introduced in France and will come into effect from 1 January 2018. It is expected that the withholding tax will be processed
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