France – Transfer pricing adjustments been recognized by the Appellate courts
The Administrative Courts of Appeal of France recently issued decisions affirming transfer pricing adjustments which are as follows: Lyon court of appeals The Administrative Appeals court in Lyon concluded that Frenchco exercised direction and
See MoreFrance – Administrative Court of Appeal of Paris denies use of secret comparables
The Administrative Court of Appeal of Paris gave its decision in Nestlé Entreprises v. Minister of Economy and Finances (No. 12PA00469) on 5 February 2013 concerning the use of secret comparables under the transfer pricing regulation, article 57 of
See MoreInterest income under the income tax treaty between Vietnam and France
The income tax treaty between Vietnam and France does not provide any provisions for the taxation of interest derived from transactions of loans. Recently Vietnam has provided guidelines on certain tax provisions of the treaty. According to the
See MoreFrench Assembly Passes Tax Evasion Bill
The French National Assembly has definitively adopted the Government's anti-tax evasion and major economic and financial crime bill. The legislation was passed by 358 votes to 198. The bill is designed to considerably strengthen the capacities of
See MoreFrance – Update on proposed tax legislation
The proposed tax changes contained in the legislation are expecting to execute the package of Finance Bill 2014 of France. According to the proposed legislation pending before the French Parliament the surcharge on corporate income tax would be
See MoreFrance – Additional reporting requirements for companies
The national assembly of France passed a legislation related to reporting requirements on 5 November 2013. The legislation consists of new reporting requirements in addition to transfer pricing documentation for companies. Companies which will fall
See MoreFrance to Renegotiate HGV “Eco Tax” Contract
The French Finance Minister has announced plans to renegotiate the contract concluded with the Italian-led consortium Ecomouv. The contract is charged with implementation of the country’s controversial heavy goods vehicle (HGV) eco tax, to
See MoreFrance Observes “Influx” Of Voluntary Tax Declarations
According to a report on 6 November 2013 around 4,000 taxpayers have submitted a voluntary declaration to the country's Tax Administration over the course of the past four months, to regularize their tax situation. The "influx" of requests followed
See MoreFrench Lawmakers Return to Tax on Energy Drinks
The National Assembly of France has adopted the social security finance bill 2014. The assembly also included an amendment for the introduction of a tax on energy drinks. There are also provisions to harmonize social levy rates imposed on savings
See MoreFrance: Mandatory Online Tax Reporting Threshold
The French Finance Ministry announced on 17 October 2013 a reduction in the threshold for application of the mandatory on-line reporting obligations, for companies in France not subject to corporation tax (IS) in 2013-2014. From October 1, 2013,
See MoreFrance: New 1% tax on EBITDA repealed
The French Minister of Economy officially announced on 6 October 2013 that the new 1% tax on Earnings before Interest, Tax, Depreciation and Amortization (EBITDA) will be repealed and a new temporary surtax on the corporate income tax will be
See MoreFrance -Revision to VAT rates
The government of France is planning to raise the current standard VAT rate from 19% to 20 % and to increase the intermediate rate of VAT from 7% to 10% from 2014. This will increase the fiscal burden on households in France by around EUR 6bn
See MoreFrench: Corporate Tax Plans
On 27 September 2013 the French Government announced plans to introduce a "contribution on the gross operating surplus" of a company, within the framework of its 2014 finance bill. Marking an important change to corporate taxation, the Government
See MoreFrance -Presents Finance Bill 2014
The French Finance Minister and Budget Minister presented the country’s 2014 finance bill to the Council of Ministers on 29 September 2013, providing for a number of tax measures designed to increase employment and to modernize and preserve
See MoreFrance: Considers EU Data Transfer Tax
Reports suggest that France aims to put forward the idea of a tax to be imposed on data transfers outside of the European Union (EU) at the upcoming European summit meeting due to be held on October 24 and 25. Together with Germany and the UK,
See MoreFrench Tax Bills for 2014 announced
On 11 September 2013 the French Finance Ministry finalized its 2014 finance bill. The tax burden on the wealthiest individuals in particular will continue to rise, despite the Government's pledge to stabilize taxes next year. The French Government
See MoreFrance: Temporary reduction on taxation capital gains on immovable property
The government of France issued guidelines BOI-RFPI-PVI-20-20-20130809 on 9th August 2013, providing new reductions on capital gains for the purpose of individual income taxation and social contributions. The reduced tax rate is 25%. Moreover, the
See MoreFrance: List of non-cooperative states or territories updated for 2013
The French government published a Ministerial Decree on 28 August 2013 updating the list of non-cooperative states or territories (NCSTs). The list will become effective from 1 January 2013. A major consequence for a country that is on the list of
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