Lapeyre, Wolters Kluwer, Xerox, … The last two years have been marked by a new type of dispute, characterized by the incursion of the civil judge in the determination of
Ruthy Zaghdoun
France
The Google case : lack of VAT establishment in France
Google Ireland Limited (GIL) provides to French customers, in accordance with a contract signed with Google France (GF), advertising services via the research engine “AdWords”. In its decision, the Administrative
3% Dividend Tax : unconstitutionality proclaimed by the Constitutional Court – Claims can still be filed for the 3% Tax paid in 2015, 2016 and 2017
The Constitutional court, in its decision #2017-660 QPC of October, 6 2017 rules that the 3% dividend tax in its entirety is contrary to the Constitution (Articles 6 and 13
Creation of a procedure of hearing for anyone who can provide information on breaches relative to tax fraud and international tax evasion
Through communication right, the French tax authorities (FTA) had already the right to obtain documents held by thirds parties in order to establish tax base and to control the tax.
News on transfer pricing obligations in France: towards documentation for all
Two major changes in filing obligations are to be noted: The threshold above which a taxpayer should file the transfer pricing return(formulaire 2257 SD, Article 223 quinquies B du CGI)
Capital gains on the disposal of equity holdings: calculation of the proportion of fees and charges
Administrative Supreme Court Decision, June 14, 2017 For accounting periods ending on or after 31 December 2012, the 12% portion of fees and charges is assessed on the gross amount
CVAE – Tax consolidation litigation – Repayments can still be obtained
French companies have to file claims in order to obtain the restitution of the French CVAE (Cotisation sur la valeur ajoutée des entreprises) paid in 2016 and 2017. The French
CVAE – Tax consolidation litigation Claims to be filed now
Supreme Court decisions of March 1st, 2017 French companies should take precautionary action now in order to claim the French CVAE (Cotisation sur la valeur ajoutée des entreprises) paid
3% Surtax on dividends: Preserve your rights to restitution
With the decision of the Constitutional Court of September 30, 2016, the conclusion of the Advocate General Kokott on the Belgium Fairness Tax last week and the Financial law presented
Dividends received from 95% outside EU held subsidiaries: French corporate tax paid on the fixed proportion of costs and expenses should be claimed
As released in our Tax Alert dated 2 September 2015, the Court of Justice of the European Union concluded in the Groupe Steria SCA case (C-386/14) that the differentiated taxation