Our tax alerts

  • I. CORPORATE TAXATION • Financial expenses ceiling: the French Tax Authorities (“FTA”) are launching a public consultation on their comments – BOI-IS-GPE-20-20-110 of July 31st, 2019 Although they may be amended following the consultation that ends on September 30th, 2019, the FTA comments are enforceable......

  • I. CORPORATE TAXATION Withholding tax: application on deemed distribution – Judgement of the Montreuil Administrative Court (“TA”) on May 9th 2019, n°1800847, Société Compagnie Gervais Danone The TA considers that a French company may request the discharge of a withholding tax on deemed distribution to......

  • I. CORPORATE TAXATION • Interest rate: comparables drawn from the bond market – Judgement of the Versailles Administrative Court (« TA ») on April 4th 2019, n°1607393 and 1606803, SAS Wheelabrator Group The Versailles TA ask for the opinion of the French Administrative supreme Court......

  • Claim to be introduced by non-French tax residents who have paid social security contributions on French source real estate income and capital gains French source real estate income and capital gains received by non-residents are subject to French social security contributions. For the record, the......

  • I. CORPORATE TAXATION Interest between related companies: determination of the fair market rate – Decision of the Paris Administrative Court of Appeal (“ACA”) on December, 31st 2018, n°17PA03018, SAS WB Ambassador According to the ACA, the presentation of a loan offer or a study contemporary to......

  • I. CORPORATE TAXATION I.1. Corporate Income Tax (« CIT ») Definitive losses of a European subsidiary: a deduction supervised – Judgement of the Montreuil Administrative Court (TA) on January 17th 2019, n°1707036 The Montreuil TA has just ruled that a French parent company, head of......

  • I. CORPORATE TAXATION I.1. Corporate Income Tax (« CIT ») • Decrease and increase of the equity: impact of an equity reduction on the purchase price of the shares – Decision of the French Administrative Supreme Court (“CE”) on November 28th, 2018, No. 417875 The......

  • I. CORPORATE TAXATION I.1. Corporate Income Tax (« CIT ») • Finance Act (« FA ») 2019: developments in terms of corporate taxation – Provisions enacted on December 28th, 2018 Deduction of the financial expenses (Section 34): companies that are not thin-capitalized may deduct their......