France: US Multinational Groups and the French Country-by-Country reports
The United States hasn’t been yet included in the French Ministerial Order consisting of the list of states for CbCR purposes. Discussions on the authority agreement between France and USA are still going on, which has a bit of suspense running
See MoreFrance : Temporary Exceptional Surcharge on Large Companies
The French Constitutional Court finalized the “exceptional surcharges” to levy on corporate income of the French largest companies. This exceptional surcharges apply to French companies or branches that are subject to corporate tax, and have
See MoreFrance: Country-by-country reporting
On 5 December 207, the French tax authorities released a new rule regarding the country-by-country (CbC) reporting obligations provided for by article 223 quinquies C of the French General Tax Code. According to OECD guideline jurisdictions
See MoreFrance: Parliament approves the first Amending Finance Bill for 2017
The French Parliament has approved the first Amending Finance Bill for 2017 that was validated by the French constitutional court. The administrative guidelines on temporary surcharge of large companies were released on 8 December 2017. This Bill
See MoreFrance: Constitutional Court confirmed its judgment on temporary surcharge on large companies
The French Constitutional Court declared its judgment on the recently approved temporary surcharge on large companies on the 29 November 2017. More than sixty Senators and more than sixty MPs criticized the procedure for passing the law. The
See MoreFrance: Government publishes draft second Amendment Financing Act for 2017
On 15 November 2017, a second draft amending Finance Bill for 2017 was submitted to the French Council of Ministers and was submitted to the French Parliament. The draft law emphasized the following tax measures for the coming year. Anti-Evasion
See MoreFrance: “exceptional surcharges” proposed for corporate tax of large companies
On 2 November 2017, the French government announced details of proposed “exceptional surcharges” which will be 15% and will be imposed on corporate income tax due by companies with gross revenue exceeding EUR 1 billion for financial years ending
See MorePakistan approves updating tax treaties with Sri Lanka, Nepal, France, Tunisia, Morocco, and Portugal
On 10 October 2017, the federal cabinet has granted approval to amend existing conventions on avoidance of double taxation treaties with Sri Lanka, Nepal, France, Portugal, Tunisia and Morocco for avoiding double taxation and the prevention of
See MoreFrance: Draft finance bill for 2018 released
The government of France released the draft Finance Bill for 2018 on 27 September 2017. The main changes outlined in the draft Bill are as follows: Decrease of the French corporate income tax rate Elimination of the 3% tax on dividend
See MorePakistan: Cabinet approves amending taxation treaties with Finland, Italy, and Turkey
The federal cabinet on 7 September 2017, approved amending the existing conventions of avoidance of double taxation treaties with Finland, Italy, and Turkey. The cabinet, which chaired by Prime Minister Shahid Khaqan Abbasi, given approval to amend
See MoreFrance: Planning to remove CICE Tax Credit
With the aim of creating a more business friendly environment, the French Government is planning to remove the competitiveness and employment (CICE) tax credit and reduce social security contributions. As an approach on this, the CICE tax credit
See MoreFrance: list of cooperating jurisdictions on CbC reporting requirement published
A list of jurisdictions that have introduced Country-by-Country reporting requirements and have concluded a competent authority agreement on the automatic exchange of CbC reports with France was published in the French Official Journal on 8 July
See MoreSwitzerland and France resolve tax information exchange cases
According to a statement by the Swiss Federal Council, Switzerland and France have resolved a number of questions concerning the exchange of tax data. The statement confirmed that the authorities had succeeded in agreeing on common solutions. The
See MoreFrance: Reduction of corporate tax rate confirmed
On 4 July 2017, the Prime Minister of France confirmed in his opening speech to the National Assembly that the Government would cut the corporate tax from 33 percent to 25 percent by 2022 with the hope of attracting Businesses so that they set up
See MoreFrance: Implementation of withholding tax postponed for one year
The newly elected Prime Minister of France delayed the implementation of withholding tax further by one year, which means this will now enter into force on 1 January 2019. However, the decision will be confirmed by formal vote of the French
See MoreFrance: CJEU rules on 3% contribution on distributed profits
In France, companies subject to Corporate Income Tax (CIT) are required to pay an additional CIT contribution of 3% on the distributed profits according to article 235 ter ZCA of the French general tax law. But, the Court of Justice of the European
See MoreFrance: New tax plans by the newly elected president
French newly elected president has committed to reduce the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years. The tax credit on research, innovation and the start-up status
See MoreFrance: CbC reporting notification and filing obligation
The country reporting (CbC) obligation in France contains a notification according to which French companies subject to the notification obligation are required to mention in their annual corporation tax returns, whether they will be submitting the
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