The European Commission has opened new possibilities for supporting research, development, and innovation (“R&D&I”) through the adoption of a revised framework for State aid in this area. The “2022 R&D&I
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
2022 finance law adopted by Parliament
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French parliament on 15 December 2021 adopted the 2022 finance
2022 draft finance bill released
France’s 2022 draft finance bill was released on 22 September 2021. Parliamentary discussions should begin on 11 October and are expected to be finalized by the end of December 2021
E-commerce : towards an all-round tracking of the transactions
In order to eradicate VAT fraud relating to e-commerce, new place of taxation rules, simplified compliance, but also a new VAT payer status impacting online marketplaces will come into force
2021 finance law adopted by Parliament
The French parliament adopted on 17 November 2020 the 2021 finance law. This article summarizes some of the law’s key provisions applicable to companies, some of which are the same
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.
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