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
Final version of DAC 6 guidelines published
This article is reproduced on this blog with the authorization of Deloitte. To see the original article, click here. On 25 November 2020, the French Tax Authorities (FTA) published the
What future for taxation in the EU?
This article comes from a webinar held on 13 May 2020 on the EU Tax Agenda organised by Deloitte EU Policy Center On 13 May 2020 we held a Webinar
Brexit – The withdrawal agreement – VAT & customs aspects
A quick update on the latest Brexit developments following the draft Brexit withdrawal agreement (the Agreement) which was released on 14 November 2018 following agreement in principle by the UK
Transfer pricing adjustments and customs: the Chinese example
Transfer pricing models implemented by Multinational Enterprises (MNE) often rely on the Transactional Net Margin Method (TNMM) to remunerate routine functions. A proper application of the TNMM involves the transfer
BEPS Corner
Action 1 On March 16th, the OECD published an interim report on the digitalization of the economy. The report is mainly an inventory of the situation, without any concrete proposal
Digital taxation: towards a European taxation?
On March 21st 2018, the European Commission published two draft directives related to digital taxation. Since the European summit in Tallinn last September, Member States have been searching the best
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
Employment protection plan and transfer pricing policy, careful to the mix of genres
If the introduction of an employment protection plan can be a complicated procedure in employment law given the legal framework that this procedure benefits from, it should moreover be noted
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