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,
See MoreFrance: 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.
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