This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French Tax Authorities (FTA) on 21 May 2025 published guidelines
High court rules controlled foreign company rules are compatible with tax treaties
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 13 March 2025 that
Decree clarifies scope of Pillar Two reporting obligations
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. In a decree (No. 2024-1126) published on 5 December 2024, France
2025 finance bill adopted by Parliament
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 6 February 2025, France’s 2025 finance bill was adopted by
FTA guidelines address denunciation of tax treaty between Burkina Faso and France
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
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