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
End of exemption from surtax on distributions within tax-consolidated groups: no retroactive effect the French Government announced
The French Government has just announced that the end of the exemption from 3% surtax on distributions within tax consolidated groups will not have a retroactive effect.
French FTT: Taxation of intraday transactions and higher rate?
On Wednesday night, members of the French Parliament have voted an extension of the scope of the French financial transaction tax (FTT) aiming at including intraday transactions and an increase
Surcharge of 3% on dividends: The exemption in favor of tax consolidated groups contrary to the French constitution
The constitutional Court rendered its decision n°2016-571 QPC on September 30, 2016 and decided that the exemption of the 3% tax for distributions made inside a tax consolidated group provided
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
French Corporate Income Tax Surcharge of 3% on Dividends: Claims to be filed now
Supreme Court decisions of June 27, 2016 French companies should take precautionary action now in order to claim the French corporate income tax surcharge of 3% paid in 2014, 2015
Exlusion of the parent/subsidiary regime for non-voting shares provided by article 145-6b ter codified now in article 145-6c of the French tax code: Claims to be filed now
As a reminder, article 145-6b ter of the French tax code (now codified in identical terms under article 145-6c of the French tax code) excludes from the benefit of tax
French corporate income tax surcharge of 3% on dividends: buy-back of shares achieved before January 1st, 2015
French companies must claim the 3% surtax paid in 2014 relating to a buy-back of shares by the deadline of December 31, 2016. The Surpreme Court, by a decision of April
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
French corporate income tax surcharge of 3% on dividends: Claims to be filed now
French companies should take precautionary action now in order to claim the French corporate income tax surcharge of 3% paid in 2014, 2015 and 2016. Last week, a so called