In a decision dated 28 July 2017 (CE n°411269), the French Supreme Court ruled not to refer to the French Constitutional Council the priority constitutionality question (“QPC”) brought by Société
Small-sized, medium-sized companies: Transfer pricing form’s threshold lowered
Middle-market companies and SMEs have until November 3, to fill in the transfer pricing form following the lowering of the applicable threshold to €50 million. The applicable threshold for the
Amazon: IRS loose again
In the March 23rd, 2017 decision Amazon.com, Inc. v. Commissioner, T.C., No. 31197-12, 148 T.C. No. 8, the US Tax Court concluded that the United States tax authorities had an
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.
Advice on the preparation of the Research Tax Credit justification file from the R&D Tax Credit guide (2017 edition released in April)
Every year, the French Ministry of Higher Education, Research and Innovation (MESRI) publishes an R&D Tax Credit guide for educational purposes. This guide does not have any legal or regulatory
The Research Tax Credit (RTC), a powerful tool to boost private research according to an “OFCE” report
According to the RTC impact analysis report coordinated by the French Economic Observatory “OFCE” and published by the French Ministry of Higher Education, Research and Innovation (MESRI), the business expenditures
GE Money Bank: the question of the proof of the implicit support
In transfer pricing, the question of the burden of the proof is one of the major issues at stake. The French Supreme Court (Conseil d’Etat) decision dated June 19th, 2017
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
Circular of 20 April 2017, concerning the application of late interests in case of late payment of some customs receivables
This article was first published in our monthly newsletter Indirect Tax News. This newsletter sums up the main news in indirect tax and customs. Since the 2016 Amending Finance Law,