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)
The Future of Transfer Pricing – Focus on France
This article was first published in Les Cahiers de l’IFA, volume 102, The future of transfer pricing, July 2017 Download the original version of this article This article
Country by Country Reporting: Notification obligation before December 31, 2016
In the context of the implementation of the Country by Country reporting, the OCDE offered the option for countries to introduce provisions requiring a notification from the local constituent entities
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
How to get through the fiscal Middle Ages in Europe ?
For a millennium, Europe experienced a chaotic transition from the Roman Empire order to the one of nation states that emerged during the Renaissance. During this period of time, the
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
New R&D Tax Incentive in Poland since January, 2016
Since January 1st, 2016, companies operating in Poland have been able to deduct the amount of certain R&D-related expenditures from their taxable base. More specifically, they can deduct: 130% of
Reclaiming withholding tax in France – Practical difficulties…
Continuing in the line of the Aberdeen case law, the ECJ confirmed on 10 May 2012 in their Santander decision that withholding tax levied in France on dividends paid to
In Memorium – A Tribute to the Father of EU Corporate Tax – Professor Albert J. Rädler (1933- 2012)
Rick Minor is a lawyer and e.commerce policy expert based in Luxembourg. He had the privilege to work with Professor Rädler in the firm´s Munich office from 1991 to 1994.
Current issues in EU tax litigation in the UK courts
The last decade has seen a significant increase in litigation in the United Kingdom in which taxpayers have challenged various provisions of the UK corporate tax legislation on the basis