This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French tax authorities (FTA) on 1 March 2023 updated their guidelines

FTA guidelines explain how to offset foreign tax credits against social surcharge

Ownership threshold for tax consolidation group may consider cross-shareholding
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. <pclass=”intro”>>The French Administrative Supreme Court overturned on 1 March 2023 an

List of noncooperative states and territories updated
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s list of noncooperative states and territories (NCSTs) was updated on 5 February 2023 (following

FTA publishes new DAC 7 administrative guidelines
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. A decree setting out rules relating to the new DAC

High court rules nil remuneration rate in cash pooling arrangement may be proper
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s Supreme Administrative Court (SAC) held in a transfer pricing

2023 draft finance bill released
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s 2023 draft finance bill was released on 26 September 2022.

Five EU member states issue joint release committing to implement Pillar Two in 2023
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 9 September 2022, representatives from France, Germany, Italy, the Netherlands, and

RTC & the concept of public subsidy
Paris Administrative Court of Appeal judged that the subsidies paid by the professional committee for the development of the French wood furniture industries (CODIFAB) and by the national inter-professional association

High court rules that social contributions are covered by tax treaties
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French Administrative Supreme Court ruled on 14 April 2022 that

Tax consolidation: Steria does not extend to dividends paid by non-EU companies
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. In two decisions issued on 14 April 2022 (n° 19VE03912 and