France Pushes Ahead On FTT
Embarking on a lonely and uncertain course, France’s long-awaited, much debated tax on financial transactions (FTT) finally entered into force on 1 August 2012. Supposedly prefiguring the introduction of a mechanism at European level, a 0.2% tax
See MoreFrance- Transfer Pricing Rules
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
See MoreFrance: Property Savings Account Tax Perk to remain
The Budget Minister of France has confirmed that there are no plans to change regulated home buyers savings account (PEL savings account). This measure enables individuals to earn tax free interest earned up to a period of 12 years, and offers
See MoreProtocol to Canada- France DTA enters into force
The Protocol amending the Canada-France DTA signed on 2 February 2010 entered into force on 27 December
See MoreFrance: Tax provisions enacted
The French Parliament passed the tax legislative packages for 2014 on 19 December 2013, which were subsequently scrutinized by the Constitutional Court on 29 December 2013 and eventually enacted into law on 30 December 2013. Most of the key
See MoreFrance – Finance Bill 2014 enacted Transfer Pricing Provisions
The Finance Bill for 2014 of France was published on December 30, 2013. The bill contains transfer pricing provisions but the Constitutional Court has rejected certain controversial provisions. As approved by the Constitutional Court the Finance
See MoreFrance-Canada DTA protocol approved
In accordance with initial media reports, France's lower house of parliament approved the protocol to the Double Tax Agreement signed with Canada on December 23,
See MoreFrance – Status of Transfer pricing proposals in the Draft Finance Bill for 2014
The French Senate rejected part 2 of the draft finance bill for 2014 on 16 December 2014. The bill is scheduled on 19 December 2013 for a final consideration. The draft bill changes the penalty provisions for those taxpayers who fall under article
See MoreFrance: Independent Worker Union Criticizes Corporate Land Tax Reform
The government of France proposed reform to the corporate land tax contribution (CFE) under the framework of the finance bill of 2014- PLF 2014. But the independent worker union UNAPL has strongly criticized the proposal. The PLF 2014 presents
See MoreFrance-Increase of VAT rate from 1 January 2014
The government of France announced on 16 December 2013 to reduce the VAT rate from 19.6% to 20% in 2014. The increased VAT rate should be applied on all taxable supplies from 1 January
See MoreFrance – “Abridged” transfer pricing documentation to be filed annually
On 12 December 2013 it was reported that recently enacted transfer pricing legislation includes a new requirement for large taxpayers to file annually an “abridged” version of their transfer pricing documentation. The requirement to file the
See MoreFrance and the US signed FATCA Intergovernmental Agreement
On 14 November 2013, the US and France signed an Intergovernmental Agreement (IGA), in order to improve international tax compliance and to implement the US Foreign Account Tax Compliance Act. The FATCA legislation aims to ensure that US citizens
See MoreFrance – Arm’s length indemnification for unfair termination of contracts
In two court cases of France it was reported on 9 January 2013 that a failure to provide the required notice period with respect to a group restructuring may provide a cause of action for an award of compensation for unfair termination of a
See MoreFrance – 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
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