This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. Further to its July 2022 decision that the add-back of a 5%
High court rules nil remuneration rate in cash pooling arrangement may be proper
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s Supreme Administrative Court (SAC) held in a transfer pricing
2023 draft finance bill released
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s 2023 draft finance bill was released on 26 September 2022.
High court rules that social contributions are covered by 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 14 April 2022 that
Tax consolidation: Steria does not extend to dividends paid by non-EU companies
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. In two decisions issued on 14 April 2022 (n° 19VE03912 and
Brexit FAQs updated
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) updated on 14 January 2022 their FAQs (in
Administrative Supreme Court rules on treatment of sale of US partnership interests
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 gains
Young Doctors: useful details on the concept of first recruitment
Under the Article 244 quarter B, II, b of the French Tax Code, staff costs relating to staff holding a doctorate, directly and exclusively assigned to research operations, shall be
Social contributions and internal monitoring: positive news on the eligibility of expenses for the RTC
The Council of State has ruled that the exceptional and temporary contribution (CET), payable by companies belonging to an institution under the AGIRC, constitutes a social contribution to be considered
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