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Corporate Tax
Group Taxation
Office Dépôt decision: the principle of non-deductibility of shareholder costs at the level of the subsidiaries of a group
CbCR: situation of French subsidiaries of foreign entity residing in a state that does not apply the automatic exchange of information
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
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National Tax
French Parliament adopts 2020 finance bill
French income tax withholding: Measure your readiness !
French income tax withholding: focus on foreign employers and secondees to France
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International Tax
Brexit – The withdrawal agreement – VAT & customs aspects
Brexit: Deal or No Deal? A Snapshot of the immigration implications
Transfer pricing adjustments and customs: the Chinese example
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Transfer Pricing
European Commission Targets Member States’ Tax Rulings as Prohibited State Aid: Where Will it Lead?
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
Profit split: uncertainty remains
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BEPS – OECD/EU
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
Profit split: uncertainty remains
Taxation of the digital economy: new developments, but not yet over
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Individual Tax
Global Rewards
French social surtaxes: refund claim opportunities
Significant changes to french trust reporting obligations
French Equity Savings Plan (PEA) & Brexit – Which impact on funds invested in British securities?
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International Mobility
Coronavirus and Social Security: removal of the waiting period for French expatriates
Home country working for cross borders workers and multiple countries activity: EU Social Security Regulation & Covid-19
Posted workers into France: new provisions, however insufficient! (Decree and Circular of 4th June 2019)
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Private Clients
Trust update: Extension of the Trustees reporting obligations… again
Financial Services Reward Update – CRD V and CRR II
Tax domicile in France of French major companies’ corporate executives
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French Taxation
Trust update: Extension of the Trustees reporting obligations… again
French Parliament adopts 2020 finance bill
Tax domicile in France of French major companies’ corporate executives
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Indirect Tax
French VAT
13
rd
Directive VAT refund : extension of the filing deadline until September 30, 2020
Covid-19 : the reduced VAT rate of 5.5% is now applicable to supplies and intra-Community acquisitions of certain protective equipment and personal hygiene products.
Covid-19 and the french VAT returns: Tax authorities propose new practical arrangements for businesses facing difficulties
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European VAT
New guidelines for non-EU exporters released
Exports of personal protective equipment are now subject to authorisation!
Skarpa Travel s.p. European case: important clarifications regarding the VAT Tour-Operating margin scheme (TOMS)
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Bank, Finance, Insurance
Morgan Stanley Case-Law (C-165/17), January 24th, 2019
Scope of the VAT exemption applicable to transactions performed by insurance intermediaries
VAT treatment of groups of persons formed in the financial and insurance sectors
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Real Estate VAT
VAT qualification of a finance lease with an option to purchase
VAT deduction on intermediation expenses incurred in the frame of a sale subject to the VAT exemption regime of article 257 bis of the FTC
VAT election to be liable for VAT on rents
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E-Commerce
E-commerce: clarification about the obligations laying on logistic warehouses operators
Several liability to the payment of VAT for online platform operators: opening of a public consultation regarding new French tax administration guidelines
“YouTube” and “Netflix” tax: publication of the implementing decree
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Customs & Global Trade
Coronavirus: don’t forget to answer the Chinese Customs survey!
Several liability to the payment of VAT for online platform operators: opening of a public consultation regarding new French tax administration guidelines
COVID-19: the French Government takes a favorable measure for businesses in a VAT credit position
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Export Control
Eleventh package of restrictive measures against Russia: beware of export diversions, particularly for products containing semi-conductors!
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Research & Development
“CIR” Tax Scheme
Taxation of proceeds from the assignment or grant of patents: what’s in the new administrative comments ?
The Research Tax Credit (RTC) case law deals with the eligibility of seasonal workers in agriculture
Coronavirus – Immediate repayment of the RTC receivables to be refunded in 2020
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“CIR” and Public Debate
Ministry for Higher education and Research’s guide for 2019
Research Tax Credit – A disappointing “counter-expertise”
Finance bill for 2020 – Research Tax Credit (RTC): a proposal for decreasing operating expenses
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Intellectual Property
The French-style IP box: reform of the tax regime on the proceeds from the sale or licensing of patents (Art. 14 of the FLP – new Article 238 of the CGI)
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Governmental Tax Incentives
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
The 2017 Deloitte “Survey of Global Investment and innovation incentives” has been released
Tax incentives for research and innovation in France and worldwide
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Tax Controversy
Computerized Tax Audit
Computerized tax audit – 2016 Amending finance law
Accounting examination – 2016 Amending Finance Law
Certified cash register system & accounting/management software
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Tax Controversy
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
Capital gains on the disposal of equity holdings: calculation of the proportion of fees and charges
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Legal
Corporate Law
Tax implications of a rent waiver in the context of the current sanitary crisis
The pre-pack asset sale plan: an effective tool for taking over a distressed French business
Non-performing loans: in order to increase the effectiveness of bank securities in the event of outstanding debts
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Public Law
Social contributions and penalties: changes introduced by the Social Security Financing Law for 2018
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Labour Law
Posting of workers in the framework of the provision of services: revision of the Directive of 16 December 1996
Calculation of profit-sharing challenged by the Unions: the French Supreme Court closes Pandora’s Box
FOCUS ON the French labor law reform: the new outlines of the text definitively adopted
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Industries
Financial Services
Financial Services Reward Update – CRD V and CRR II
Interests of bonds convertible into shares and VAT prorata
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
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Real Estate
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
VAT qualification of a finance lease with an option to purchase
VAT deduction on intermediation expenses incurred in the frame of a sale subject to the VAT exemption regime of article 257 bis of the FTC
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Digital
Recovery of VAT on costs incurred in the event of an unrealized transfer of securities
The national data protection authority (CNIL) has published its opinion on the draft bill amending the French data protection act for the implementation of the GDPR
Taxation of the digital economy: new developments, but not yet over
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Insurance
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“CPF” Think Tank
Sylvain Cuvigny
Deloitte Société d'Avocats
Sylvain Cuvigny
Deloitte Société d'Avocats
France
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