As a reminder, this guide, which does not have any legal or regulatory value (and is not enforceable against the administration) is intended to help companies in their Research tax
Tax Collection At Source reform: secure the tax treatment of “non-qualified” equity gains
The Tax Collection At Source reform (“Prélèvement à la Source” or PAS, in French), which will enter into force on January 1st, 2019, will be a game-changer for companies that
BEPS Corner
Action 1 On March 16th, the OECD published an interim report on the digitalization of the economy. The report is mainly an inventory of the situation, without any concrete proposal
Digital taxation: towards a European taxation?
On March 21st 2018, the European Commission published two draft directives related to digital taxation. Since the European summit in Tallinn last September, Member States have been searching the best
Office Dépôt decision: the principle of non-deductibility of shareholder costs at the level of the subsidiaries of a group
The administration benefits from the rebuttable presumption of indirect transfer of profits abroad if it demonstrates the existence of a “relationship of dependency” between a French entity and a foreign
Employment protection plan and transfer pricing policy, careful to the mix of genres
If the introduction of an employment protection plan can be a complicated procedure in employment law given the legal framework that this procedure benefits from, it should moreover be noted
CbCR: situation of French subsidiaries of foreign entity residing in a state that does not apply the automatic exchange of information
Under OECD recommendations, jurisdictions should require, in a timely manner, the filing of Country-by-Country declarations by the ultimate parent companies of MNE group resident in their countries and exchange this
The US tax reform: some thoughts on transfer pricing aspects
The United States have demonstrated a great fiscal stability in recent years. However, when the United States decide to reform their tax system, it is a revolution: the reduction of
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
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
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
In order to benefit from the presumption of transfer of profits attached to article 57 of the French Tax Code (“FTC”), authorities must produce a double proof: Evidence of a