France: Implementation of withholding tax postponed for one year
The newly elected Prime Minister of France delayed the implementation of withholding tax further by one year, which means this will now enter into force on 1 January 2019. However, the decision will be confirmed by formal vote of the French
See MoreFrance: CJEU rules on 3% contribution on distributed profits
In France, companies subject to Corporate Income Tax (CIT) are required to pay an additional CIT contribution of 3% on the distributed profits according to article 235 ter ZCA of the French general tax law. But, the Court of Justice of the European
See MoreFrance: New tax plans by the newly elected president
French newly elected president has committed to reduce the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years. The tax credit on research, innovation and the start-up status
See MoreFrance: CbC reporting notification and filing obligation
The country reporting (CbC) obligation in France contains a notification according to which French companies subject to the notification obligation are required to mention in their annual corporation tax returns, whether they will be submitting the
See MoreFrance: Amending Finance Act for 2016 adopted
The Amending Finance Law for 2016 was published in the Official Journal of 30 December 2016 after going through a ruling of the Constitutional Court on the compatibility of the provisions of the law. The Court ruled that the provisions allowing the
See MoreFrance –Published Finance Law for 2017
In France, the Financial Law 2017 had been published under Law No 2016-1917 on 30 December 2016. On 29 December 2016, the Constitutional Court issued its decision on the comparability of certain provisions of the Financial Law 2017 with the
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and India of 1992 activated
The most-favored-benefit clause of the Income and Capital Tax Agreement between France and India of 1992 was activated. As a result, the applicable tax rate and the amount of the withholding tax on dividends, interest, royalties and remunerations as
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and Estonia of 1997 activated
The Income and Capital Tax Treaty of 2014 between Estonia and Luxembourg activated the MFN clause of the protocol to the treaty between France and Estonia of 1997. As a result, interest paid to any kind of loan of whatever kind granted by a bank, as
See MoreMFN clause of the protocol to the Egypt – France Income and Capital Tax Treaty (1980) (as amended through 1999) activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. As a result, the MFN clause in article II of the protocol to the Egypt -
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and Chile of 2004 activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. Accordingly, the MFN clause in paragraph 6 of the protocol to the Chile
See MoreMost favoured nation clause of the protocol to the Bolivia – France Income and Capital Tax Treaty (1994) activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. Accordingly, the MFN clause in article 5 of the protocol to the Bolivia
See MoreFrance-CbC reporting requirements conflicting to constitution
The Constitutional Court provided its decision on 8 December 2016 regarding the compatibility with the constitution of the public country-by-country (CbC) reporting requirements introduced through the bill on transparency, the fight against
See MoreFrance-Administrative guidance published on withholding tax exemption on dividends paid to foreign investment funds
The Tax Administration of France revised the guidelines on the withholding tax exemption regime applicable to dividends paid to foreign undertakings for collective investment on 7 December 2016. According to the amended guidelines a refund
See MoreFrance-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
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