The French Government has just announced that the end of the exemption from 3% surtax on distributions within tax consolidated groups will not have a retroactive effect.
End of exemption from surtax on distributions within tax-consolidated groups: no retroactive effect the French Government announced
Supreme Court restricts the application of the Quemener case law to achieve tax free step-up of real estate assets
The French Supreme Court (CE 6 juillet 2016 n°377904, 8e et 3e s.-s, min c/ SARL Lupa immobilière France) has just issued a decision which, although ruled in a quite