This article was first published on la revue Concurrences, N°2-2023 and is reproduced on this blog with the authorization of its authors. Allegedly, tax competition has gone too far. For the
Taxpayer in loss position may not carry forward unused foreign tax credits
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 confirmed on 8 March 2023
FTA guidelines explain how to offset foreign tax credits against social surcharge
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 1 March 2023 updated their guidelines
List of noncooperative states and territories updated
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 5 February 2023 (following
FTA publishes new DAC 7 administrative guidelines
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. A decree setting out rules relating to the new DAC
Five EU member states issue joint release committing to implement Pillar Two in 2023
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 9 September 2022, representatives from France, Germany, Italy, the Netherlands, and
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
France and Denmark sign new tax treaty
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 4 February 2022 France and Denmark signed a new tax treaty,
Administrative Supreme Court rules on definition of resident for tax treaty purposes
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 2 February 2022 that
Late repayment of a RTC claim gives rise to default interest
The Council of State considers that the repayment of RTC’s claim made after the rejection (explicit or implicit) by the Administration of the claim before it, has the character of