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)
Dividends received from 95% outside EU held subsidiaries: French corporate tax paid on the fixed proportion of costs and expenses should be claimed
As released in our Tax Alert dated 2 September 2015, the Court of Justice of the European Union concluded in the Groupe Steria SCA case (C-386/14) that the differentiated taxation
End of exemption from surtax on distributions within tax-consolidated groups: no retroactive effect the French Government announced
The French Government has just announced that the end of the exemption from 3% surtax on distributions within tax consolidated groups will not have a retroactive effect.
Surcharge of 3% on dividends: The exemption in favor of tax consolidated groups contrary to the French constitution
The constitutional Court rendered its decision n°2016-571 QPC on September 30, 2016 and decided that the exemption of the 3% tax for distributions made inside a tax consolidated group provided
Dividends received from 95% EU subsidiaries: CJEU rules French tax consolidation regime infringes EU law
In an awaited decision issued on 2 September 2015 (case C-386/14), the Court of Justice of the European Union (CJEU) concludes that the difference in taxation of dividends received by
French Corporate Income Tax Surcharge of 3% on Dividends: Claims to be filed now
Supreme Court decisions of June 27, 2016 French companies should take precautionary action now in order to claim the French corporate income tax surcharge of 3% paid in 2014, 2015
French corporate income tax surcharge of 3% on dividends: buy-back of shares achieved before January 1st, 2015
French companies must claim the 3% surtax paid in 2014 relating to a buy-back of shares by the deadline of December 31, 2016. The Surpreme Court, by a decision of April
French corporate income tax surcharge of 3% on dividends: Claims to be filed now
French companies should take precautionary action now in order to claim the French corporate income tax surcharge of 3% paid in 2014, 2015 and 2016. Last week, a so called