French real estate capital gains realised by non-residents are subject to a withholding tax of 33.1/3% subsequently creditable against French CIT. With the new Finance Act for 2017, however, the
Entry into force of a new valuation method to determine the tax basis of property tax and contribution on business properties
A new method for assessing the rental value of real estate assets as tax basis for property tax and contribution on business property has entered into force as from 1
Jurisprudential recognition of the tax discount market practice
In a decision of 15 November 2016 (n°16VE00721), the Administrative Court of Versailles recognised that a company electing for the SIIC regime (French “REIT” regime applicable to listed property investment
Extension of the favourable regime applicable to capital gains on the disposal of professional premises to be turned into housings
In the framework of the fight against the housing crisis, article 210 F of the French tax code provided for a favourable tax regime under which the net capital gain
Beneficial owners to be treated as shareholders for the purpose of the French 3% tax on real estate
In a recent case law from the commercial chamber of the French Supreme Court (n°15-14528, SCI Katzoo) relating to a Luxembourg company with legal shareholders distinct from its beneficial owners,
Mergers: French prior approval contrary to EU law
On 8 March 2017, the Court of Justice of the European Union (CJEU) issued its long-awaited decision in the Euro Park case (C-14/16), concluding that the prior agreement to be
CbCR : French Tax Authorities releases the tax form
On 2 February 2017, the French tax authorities released the form 2258-SD that must be used for purposes of filing the country-by-country (CbC) report by groups falling within the scope
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
French public register of trusts declared unconstitutional
Public register of trusts, established in December 2013 by a law on action against tax fraud and serious economic and financial crime, has been accessible to everyone online as of June 30, 2016.