This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 19 June 2023, the European Commission proposed new rules for a common
International tax competition, APAs & State aid: An economic analysis
This article was first published on la revue Concurrences, N°2-2023 and is reproduced on this blog with the authorization of its authors. Allegedly, tax competition has gone too far. For the
CJEU rules former French tax consolidation scheme infringes freedom of establishment
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 11 May 2023, the Court of Justice of the European
Court confirms calculation of foreign tax credit to offset dividend lump sum add-back
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%
Taxpayer in loss position may not carry forward unused foreign tax credits
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 confirmed on 8 March 2023
FTA guidelines explain how to offset foreign tax credits against social surcharge
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) on 1 March 2023 updated their guidelines
Ownership threshold for tax consolidation group may consider cross-shareholding
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. <pclass=”intro”>>The French Administrative Supreme Court overturned on 1 March 2023 an
List of noncooperative states and territories updated
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s list of noncooperative states and territories (NCSTs) was updated on 5 February 2023 (following
FTA publishes new DAC 7 administrative guidelines
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. A decree setting out rules relating to the new DAC
State Aid & RDI: adoption of a revised framework for State aid for Research, Development, and Innovation
The European Commission has opened new possibilities for supporting research, development, and innovation (“R&D&I”) through the adoption of a revised framework for State aid in this area. The “2022 R&D&I