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
New RTC decree: one step forward, two steps back?
Decree n°2021-784 dated June 18th 2021 regarding the certification of research organizations and scientific or technical experts to whom companies may entrust the execution of research operations in application of
Research technician: no scientific degree required
Staff expenses relating to researchers and research technicians directly and exclusively assigned to R&D operations are eligible for R&D tax credit (French Tax Code, Art. 244 quater B, II b).
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
Skandia – First application by the French Administrative Supreme Court (BNP Paribas Securities Services case)
In a decision dated November 4, 2020 (no. 435295, “BNP Paribas Securities Services”), the French Administrative Supreme Court (Conseil d’Etat) has applied for the first time the “Skandia” case law
The 2021 draft French finance bill: reinstatement of a tax incentive for sale & lease back transactions to improve the cash position of operating companies
In the context of the current COVID19 economic crisis, the improvement of the cash position of the operating companies becomes a critical need. The 2021 draft French finance bill includes
RTC on staff seconded by another company: whilst possible in theory, the practical justification is rigorous and evidence based
By a 2017 ruling, the French State Council stated that the expenses of seconded staff carrying out research operations in the company premises and with its resources could be eligible
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
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
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