The French tax authorities updated their official guidelines on 29 December 2021 concerning services supplied between a head-office and a branch. These changes are intended to take into account the
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.
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