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
High court rules nil remuneration rate in cash pooling arrangement may be proper
A tale of two Pillars
This article was first published on International Tax Review and is reproduced on this blog with the authorization of its authors. Julien Pellefigue of Deloitte Société d’Avocats explains the importance
Ecological transition: what public funding for companies?
Certainly, the ecological transition is no longer at the idea stage, but it is becoming effective. This is one of the priorities of the French Recovery Plan. Europe, for its part,
US and French Authorities reach agreement on creditability of French CSG and CRDS taxes
What is the Update? US and French Authorities reach agreement on creditability of French CSG and CRDS taxes. Background: The United States generally allows a taxpayer to claim a foreign
European Commission Targets Member States’ Tax Rulings as Prohibited State Aid: Where Will it Lead?
This article was published on January 25, 2018 by the Bureau of National Affairs, Inc., Bloomberg Tax. We obtained consent of the Bureau of National Affairs, Inc., Bloomberg Tax to
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
In order to comply with OECD standards established in Action 13 of the BEPS project, the article 107 of the Finance law for 2018 updates the content of the transfer
Profit split: uncertainty remains
As part of the BEPS project, the OECD is updating its applicable transfer pricing guidelines. One of the most controversial issues in this update is the use of profit split.
Case law WB Ambassador: storm warning on intra-group loans?
In its decision of July 7, 2017 (TA Paris, 7 July 2017, n°1607683, WB Ambassador), the TA of Paris retains a strict assessment of the provisions of article 212-I of
What future for rulings following the European Commission’s offensive?
At the time of Paradise Papers’ revelations about numerous tax schemes involving large international groups, it is interesting to look back at the activism of the European Commission, which has
CbC Reporting: Situation of French Subsidiaries of American Groups
The French tax administration has officially indicated this morning that subsidiaries and PEs in France of foreign MNEs, including US groups, do not have to file a CbCR in France