This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 17 July 2024, the French tax authorities (FTA) published guidelines
Administrative Supreme Court rules final foreign branch losses may not be deducted
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 26 April 2024 that
Horizontal consolidation is not contrary to nondiscrimination clause in tax treaty
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The Administrative Court of Appeal of Paris ruled on 1 March
2024 French Finance Bill: a Focus on HTVI Related Measures
The 2024 French Finance Bill, officially known as law n°2023-1322, was passed on December 29, 2023. It brings in new regulations aimed at strengthening the requirements for transfer pricing documentation
2024 French Finance Bill: Enhanced Oversight Targeting Transfer Pricing
The 2024 French Finance Bill (law n°2023-1322) was adopted on December 29, 2023, and has introduced new measures reinforcing transfer pricing documentation requirements as well as the power of control
List of noncooperative states and territories updated (February 2024)
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
Court clarifies full 20% tax credit applies to royalties under France-Tunisia treaty
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French Conseil d’Etat (Administrative Supreme Court) ruled on 19 February
Most favored nation clause in France-Kenya tax treaty is triggered
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. In binding comments issued on 27 December 2023, the French tax
2024 finance bill becomes law
On 30 December 2023, France’s 2024 finance law was published in the Official Journal (law 2023-1322 of 29 December 2023). This article summarizes the key tax provisions applicable to companies.
Withholding tax on dividend paid to loss-making nonresident company is constitutional
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s Constitutional Council ruled on 6 October 2023 that the withholding