France: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
See MoreFrance: Government includes some incentives to the draft Finance Bill 2022
On 16 November 2021, Some incentives for innovation were included in the Finance Bill 2022, which would have enacted by the end of December 2021. Those incentives are given below: The timeline of company’s Young Innovative Enterprises (JEI)
See MoreFrance: Government presents 2022 Finance Bill to National Assembly
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, presented 2022 Finance Bill to the National Assembly. Some of the proposed changes of this
See MoreUS: IRS publishes joint statement with France on the exchange of CbC reports
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 country-by-country
See MoreFrance: Government publishes a Law on amending Finance Act 2021
On 20 July 2021, the Government Officially published Law 2021-953 on amending Finance Law for 2021, which includes measures for loss carryback relief, new rules for withholding and capital gains from the disposal of shares, and the extension of
See MoreFrance: Filing due date extends for loss making companies in EEA to claim WHT refund
On 28 June 2021, the Tax Authority made an announcement that the submission deadline is postponed until 30 June 2021 for loss-making non-resident companies in the European Economic Area (EEA) to claim a refund for tax withheld on certain income,
See MoreFrance: Government presents draft Finance Bill 2021 in the National Assembly
On 2 June 2021, Government published the amended draft Finance Bill 2021 in the National Assembly, which proposes to temporally ease conditions related to the carryback mechanism applicable to tax losses. According to the Bill, companies will be
See MoreFrance: Government announces new tax measures due to COVID-19 pandemic
On 2 March 2021, the Government announced new tax measures for companies impacted by Covid-19, which includes methods of how to calculate corporate tax, early repayment of refundable tax credits. Methods of calculating CIT payments According
See MoreFrance: Court makes decision to reflect intra-group financial transactions
The French tax administration (FTA) published some decisions issued by the French courts and an administrative guidance regarding the arm’s length nature of intragroup financial transactions. Court’s decisions: In the last quarter of
See MoreFrance: Government publishes a country list with no CbC reporting obligation
On 3 February 2021, Government published a Decree of 3 February 2021, amending the order of July 6, 2017 amended in accordance with II of article 223 quinquies C of the general tax code. The decree comes into force the day after its publication.
See MoreFrance: Government publishes new voluntary tax compliance audit program
On 13 January 2021, the Government published a new voluntary tax compliance audit program for taxpayers to use in addressing and correcting their mistakes while at the same time, allowing the tax authorities to improve the efficiency of tax audits.
See MoreFrance: Supreme Administrative Court makes a decision regarding TP disputes
Recently, the Supreme Administrative Court made a decision of a case “France vs Ferragamo France” against of Administrative Court. On 23 November 2020, the Administrative Court made a decision in this case in favour of Ferragamo and dismissed
See MoreFrance: Government publishes Finance Law for 2021
On 30 December 2020, the Government Officially published Finance Law for the year 2021. On 17 December 2020, the French Parliament approved the Finance Bill for 2021. The Act includes: Corporate Income Tax In the context of the Covid-19
See MoreFrance: Tax Authority announces a webpage regarding DAC6 reporting
Recently, the Tax Authority has announced a webpage entitled “Déclaration des dispositifs transfrontières”, which contains french specifications for the reporting of cross-border schemes under DAC6 and the Mandatory Disclosure Rules (MDR).
See MoreFrance: Tax authorities update guidelines regarding DAC6 reporting obligations
On 25 November 2020, the tax authorities published updated guidance regarding reporting rules applicable to intermediaries as regards cross-border arrangements under the provisions of Council Directive (EU) 2018/822 (DAC6) and it provides
See MoreFrance: Finance Ministry sends notices for DST collection
On 25 November 2020, the Ministry of Finance announced that French tax authorities have begun sending notices to demand millions of euros from large digital companies or US technology groups as they push ahead with a new 3% digital services tax
See MoreIMF: Report on Economic Measures in France
On 2 November 2020 the IMF published a report following a virtual visit to France as part of the 2020 Article IV consultations. France has introduced flexible emergency support packages to provide additional stimulus from 2021 onward. An
See MoreFrance: Finance Minister announces to delay DST payments up to December 2020
The Minister of Finance, Bruno Le Maire, has recently declared that France intends to collect the country's digital services tax in December 2020, which was due in April and October 2020. The digital service tax in France will apply on the
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