France: Court issues an explanatory note and six decisions on tax evasion
The Criminal Division of the Court of Cassation published an explanatory note and delivered six important decisions (n. 1174, no. 1175, no. 1176, no. 1177, no. 1178 and no. 1179) subsequently. This explanatory note helps to explain the exact place
See MoreFrance: Tax Authority issues a Ruling on interest deduction
The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax
See MoreFrance: President signs new Law of digital services tax
The new Law No. 2019-759 has been published on July 25, 2019, in the Official Gazette, which introduces Digital Services Tax (DST). It was signed by the French President, Emmanuel Macron, on July 24, 2019. This new Law also modifies the downward
See MoreFrance issues new guidelines for GAAR
On 3 July 2019, the tax authorities published a guidelines regarding the new general anti-abuse rule (GAAR). The new GAAR, which applies from 1 January 2019, targets provisions that focus on tax-driven abuses of law. According to the guidance,
See MoreFrance publishes interest rate for shareholder loan for FY ends between June and September 2019
Recently, France has published interest rates for entities whose financial year ended between 30 June 2019 and 29 September 2019 , which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
See MoreFrance publishes interest rate for shareholder loan for FY ends between March and June 2019
On 17 April 2019, France published interest rates for entities whose financial year ended between 31 March 2019 and 29 June 2019, which are used to determine the deductibility of interest payments to shareholders. The portion of interest payments
See MoreFrance: Parliament legislates the Finance Act for 2019
The French Finance Act passed its constitutional review for 2019 on 28 December 2018. This follows the approval of the law by Parliament on 20 December 2018. The main measures of the law are summarized as follows: Corporate Income tax rate:
See MoreFrance: Parliament adopts Finance Bill for 2019
On 20 December 2018, the French Parliament approved the Finance Bill for 2019. Tax measures taken under the Finance Bill 2019: The finance bill approves interest deductibility limitation rules in effort to comply with the European Union (EU)
See MoreFrance: Court rules transfer pricing re-assessment in determining tax on added value
French tax authorities can consider income that is not “booked” in the accounts of the taxpayer-company for purposes of determining a tax on added value (“Cotisation sur la Valeur Ajoutée”—CVAE) as held by the French Supreme Tax Court
See MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
See MoreFrance ratifies MLI to implement tax treaty related measures to prevent BEPS
On 12 July 2018, France ratified the bill by way of Law No. 2018-604, as published in Official Journal No. 0160 of 13 July 2018. On 5 July 2018, the National Assembly passed the bill for the ratification of the multilateral convention to implement
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreFrance: Senate approves Multilateral Instrument (MLI)
On 19 April 2018, the Senate approved the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable France to implement international tax cooperation initiatives, including the automatic
See MoreLuxembourg and France sign new tax treaty
On 20 March 2018, Luxembourg and France signed a new income tax treaty and a new protocol, replacing the current double tax treaty signed on 1 April 1958. The Treaty contains a number of treaty-based recommendations including BEPS action 14 (making
See MoreFrance: Publishes new corporate taxation measures
The Ministry of the Economy and Finances published a summary of the main measures introduced by the Finance Law 2018 and the Social Security Finance Law 2018 regarding corporate taxation on 19 February 2018. These measures generally apply from 1
See MoreFrance: Requirement for Transfer Pricing Documentations being brought in
After disappearing from the draft, the Finance Bill 2018 undergoes revision of the last year’s requirements for transfer pricing documentation and brings in some additional changes to the requirements: Failure within the ambit of the
See MoreFrance: Change in Transfer Pricing Documentation Requirements
French Parliament updated their transfer pricing documentation rules. Under the Finance Act for 2018, which was approved by the Parliament on 21 December 2017, French companies must submit the transfer pricing documentation for financial years
See MoreUS: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
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