France- 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
See MoreBrazil issues ruling on withholding tax rate in treaty with France
Brazil has issued confirmation that there is no withholding tax on payments for technical services and technical assistance under the double tax treaty between Brazil and France. Private Letter Ruling 153/2015 on the interpretation and application
See MoreFrance: IMF comments on fiscal policy
The International Monetary Fund (IMF) issued a concluding statement on 19 May 2015 following its regular discussions with France under Article IV of the IMF’s articles of agreement. The IMF considers that although France is making a solid
See MoreFrance-Luxembourg protocol to treaty approved by Luxembourg
Council of Ministers of Luxembourg approved the amending protocol on 2 April, 2015 which was signed on 5 September
See MoreFrance: Intergroup services marked out in tax-avoidance transactions list
The French tax administration has recently published an updated list of abusive practices and fixtures that are considered to be contrary to the law. Among these are certain inter-group arrangements. Relocation of profits after restructuring:
See MoreFrance: New steps to improve relationship between tax administration and companies
The Ministry of Finances and Public Accounts and the Ministry of Economy and Industry announced a set of measures to fight tax fraud on 1 April 2015. The measures also fight against tax evasion at national, European and international level, and
See MoreFrance and Austria Seek To Launch FTT In 2016
France and Austria sought to break deadlocked talks with nine other European countries for a financial transaction tax, by proposing a broader financial transaction tax with a lower rate, in an attempt to push forward delayed plans for a European
See MoreFrance: National Assembly Approves The Treaty With Andorra
The French National Assembly approved the income tax treaty with Andorra on 20 January 2015. Further details of the treaty will be reported
See MoreFrance: Increases Transfer Pricing Documentation Penalties
France’s 2015 Finance Bill, enacted on December 29, 2014, increased the penalties applicable in cases of failure to comply with the French transfer pricing documentation rules. The newly defined penalty for a failure to produce transfer pricing
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