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,
Morgan Stanley – The Public Rapporteur presents her conclusions
On 15 March 2017, the Public Rapporteur (equivalent to the Advocate General before the CJEU) presented her conclusions in the “Morgan Stanley” case, pending in front of the French Conseil
The End of the Cost Sharing Group VAT exemption for FSI businesses?
In two opinions delivered on March 1st, 2017 (DNB BANKA C-326/15 and AVIVA C-605/15), the Advocate General KOKOTT considers that the insurance and financial sectors are not entitled to benefit
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
Supreme Court restricts the application of the Quemener case law to achieve tax free step-up of real estate assets
The French Supreme Court (CE 6 juillet 2016 n°377904, 8e et 3e s.-s, min c/ SARL Lupa immobilière France) has just issued a decision which, although ruled in a quite
Management of real estate investment funds and VAT
An important opinion was published on May 20th regarding the VAT treatment applicable to the management of real estate investment funds (Case C-595/13, Opinion, May 20th, 2015, Fiscale Eenheid X NV).
Input VAT Recovery Rights of the French branch of a Foreign Financial Institution
The Administrative Court of Appeal of Versailles recently held a decision regarding the VAT deduction rules applicable to expenses incurred by a branch established in Paris serving both its customers
Reclaiming withholding tax in France – Practical difficulties…
Continuing in the line of the Aberdeen case law, the ECJ confirmed on 10 May 2012 in their Santander decision that withholding tax levied in France on dividends paid to
VAT exemption for investment advisory services provided to management companies
ECJ confirmed in a decision dated March 7, 2013 the VAT exemption applied to investment advisory services rendered by a third party advisor to a management company of a special