France: FTA publishes update guidelines on DAC6
On 13 September 2023, the French tax authorities (FTA) revised their DAC 6 administrative guidelines in order to provide further clarification on hallmark D.1.b. This particular hallmark relates to the automatic exchange of information and
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France submits finance bill for 2024 including Pillar 2 global minimum tax
On 27 September 2023, the government of France presented the 2024 Finance Bill to Parliament. The bill aims to combat inflation, reduce the national debt and promote sustainable development. The Finance Bill includes a provision to implement the
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France updates list of exempted countries for CbC report local filing requirements
On 13 August 2023, Government published the Decree which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the the list of country exemption from local filing Country-by-Country
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France issues decree on temporary solidarity contribution for electricity producers
France has issued a decree outlining the guidelines for declaring and remitting the temporary solidarity contribution within the electricity production sector. The contribution is levied on electricity producers in France, with certain exceptions,
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France : Tax Authority issues updated guidelines on scope of digital services tax
On 21 June 2023, the French tax authority issued updated guidelines clarifying the scope of the digital services tax (DST). The guidelines, reflected in administrative documents BOI-TCA-TSN-10-10-10 and BOI-TCA-TSN-10-10-20, are in response to the
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France endorses public CbC reporting law
On 21 June 2023, France officially released Ordinance No. 2023-483, which mandates the public disclosure of CbC (Country-by-Country) reporting information. The ordinance was officially released in the French Official Journal. As per the European
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France introduces strict measures to combat international tax fraud
On 5 May 2023, French Minister for public accounts unveils anti-fraud measures targeting international tax and customs activities. Key elements of these measures include lowering the annual turnover threshold that triggers the requirement for
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France announces green industry bill with 15 key measures to secure European leadership
On 16 May 2023, as part of France's ambitions to become a leading green industry force in Europe, Finance Minister Bruno Le Maire unveiled the "Green Industry Bill." This comprehensive legislation includes a range of measures designed to propel
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France: Tax authorities issue guidelines on temporary solidarity contribution for energy sector
On 15 May 2023, the French tax authority issued comprehensive guidelines outlining the implementation of a temporary solidarity contribution aimed at certain companies operating in the fossil fuel sector. This contribution was introduced as part of
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France issues ruling on withholding tax applicable to dividend equivalent payments
On 24 February 2023, the French tax authority released two rulings related to the levy of dividend withholding tax on payments to non-residents for financial transactions that are deemed to be equivalent to dividends. In the first ruling, it is
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France: Tax Authority issues new DAC7 guidelines
On 11 January 2023, the French Tax Authority has issued guidance, known as BOI-INT-AEA-30, regarding the obligations imposed on platform operators under the new rules of the Digital Platforms Directive (DAC7). DAC7, based on Council Directive (EU)
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France publishes interest rate limits for shareholder loan
France has published interest rates for entities whose financial year (FY) ended between 31 December 2022 and 30 March 2023, which are used to determine the deductibility of interest payments to shareholders. If the interest payments exceed the
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US: IRS publishes join statement with France on exchange of CbC reports for FY 2022-2023
On 7 December 2022, the Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the French republic on the implementation of the spontaneous exchange of
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France: Court decides the statute of limitations for recovery of taxes
Recently, the Administrative Court of Montreuil issued a decision regarding the statute of limitations for the recovery of tax claims following a collection notice. The statute of limitations for recovery is 4 years, although this may be extended by
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French Court of Appeal of Paris clarifies TP rules for cross-border group companies
Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies. The taxpayer (Ferragamo France),
See MoreFrance: Government updates list of exempted countries for CbC report local filing obligations
On 14 February 2022, Government published Decree of 14 February 2022, which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the exemption from local filing provided in the
See MoreFrance: Supreme Court decides on the definition of residents for tax treaty purposes
On 2 February 2022, the French Administrative Supreme Court ruled that a company benefiting from a temporary and partial corporate income tax exemption should be considered liable to tax and therefore a tax treaty resident. The French tax
See MoreFrance: Government Officially publishes Finance Act 2022
On 31 December 2021, Government Officially published Finance Law for the year 2022. On 22 September 2021, the Minister of Economy, Finance and Recovery, Bruno Le Maire and the Minister Delegate in charge of Public Accounts, Olivier Dussopt,
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