The Paris Administrative Court considers, by its settled and recently reiterated case law (CAA Paris 16-2-2017 no. 15PA01239, Sté Vanves Solferino) that an assessment notice sent to a French translucent
Lupa case law continuation: rejection of a constitutionality question (“question prioritaire de constitutionnalité”) on the restricted scope of application of the Quemener remedy
In a decision dated 28 July 2017 (CE n°411269), the French Supreme Court ruled not to refer to the French Constitutional Council the priority constitutionality question (“QPC”) brought by Société
Small-sized, medium-sized companies: Transfer pricing form’s threshold lowered
Middle-market companies and SMEs have until November 3, to fill in the transfer pricing form following the lowering of the applicable threshold to €50 million. The applicable threshold for the
Amazon: IRS loose again
In the March 23rd, 2017 decision Amazon.com, Inc. v. Commissioner, T.C., No. 31197-12, 148 T.C. No. 8, the US Tax Court concluded that the United States tax authorities had an
Creation of a procedure of hearing for anyone who can provide information on breaches relative to tax fraud and international tax evasion
Through communication right, the French tax authorities (FTA) had already the right to obtain documents held by thirds parties in order to establish tax base and to control the tax.
GE Money Bank: the question of the proof of the implicit support
In transfer pricing, the question of the burden of the proof is one of the major issues at stake. The French Supreme Court (Conseil d’Etat) decision dated June 19th, 2017
News on transfer pricing obligations in France: towards documentation for all
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
French Election – Its Impact On Tax Policy
Given the upcoming presidential French elections, we have listed major tax and economic policy measures that could have an impact on businesses. Emmanuel Macron’s proposals Macron’s plan to cut corporate
The new withholding tax system and its impact on holders of shares in real estate funds
In the field of individual taxation, the new Finance law for 2017 introduces, with effect as from 1 January 2018, a withholding tax mechanism in France for the taxation of