On 4 December 2017, the French Administrative Supreme Court (Conseil d’Etat) issued a decision, concluding that the French tax authorities (FTA) may not reject a VAT refund claim submitted after
Lagardère: end of the story
On 13 December 2017, the French Administrative Supreme Court (Conseil d’Etat) issued a new decision according to which the rebilling, without markup, by a mix holding, of advisory costs incurred
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
VAT refund procedure for EU nonresident taxable persons in France
On 4 December 2017, the Administrative Supreme Court (Conseil d’Etat) issued a decision, concluding that the French tax authorities (FTA) may not reject a VAT refund claim submitted after 30
Focus of the labor law executive orders : the consecration of the company wide agreement (“accord d’entreprise)
The five executive orders issued to “strengthen the social dialogue” adopted on September 22, 2017, are currently in the process ratification by parliament. Among these, and spearheading the entire project
The national data protection authority (CNIL) has published its opinion on the draft bill amending the French data protection act for the implementation of the GDPR
On December 13, 2017, the French Minister of Justice presented to the Council of Ministers, the draft bill amending the French Data Protection Act. The French Government plans to publish
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.
Adjustments finally calculated on the endpoints of arm’s length range
In many transfer pricing audits, the tax authorities question the panel of comparables used by taxpayers to justify the arm’s length character of their transfer pricing policy. An adjustment is
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
CbCR: OECD clarifications on its implementation
Following on from the BEPS and in particular Action 13 reports, the OECD has recently published three important documents aiming at providing greater legal certainty for tax administrations and multinational