This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 28 December 2021, France’s Official Journal published the fourth 2021 quarterly
Employment protection plan and transfer pricing policy, careful to the mix of genres
If the introduction of an employment protection plan can be a complicated procedure in employment law given the legal framework that this procedure benefits from, it should moreover be noted
The US tax reform: some thoughts on transfer pricing aspects
The United States have demonstrated a great fiscal stability in recent years. However, when the United States decide to reform their tax system, it is a revolution: the reduction of
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
In order to benefit from the presumption of transfer of profits attached to article 57 of the French Tax Code (“FTC”), authorities must produce a double proof: Evidence of a
Customs value – Transfer pricing adjustments
The EUCJ rejects the agreed customs value between the parties, which consisted partly of an amount initially invoiced and declared and partly of a flat-rate adjustment made after the end
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.
GE Money Bank: the question of the proof of the implicit support
In transfer pricing, the question of the burden of the proof is one of the major issues at stake. The French Supreme Court (Conseil d’Etat) decision dated June 19th, 2017
News on transfer pricing obligations in France: towards documentation for all
Two major changes in filing obligations are to be noted: The threshold above which a taxpayer should file the transfer pricing return(formulaire 2257 SD, Article 223 quinquies B du CGI)
108th VAT Committee – 27-28 March 2017– Working papers
The 108th VAT Committee’s working papers report the principal subjects discussed during this meeting. The following subjects have notably been discussed: possible qualification of advisory services by credit intermediaries as
New developments in customs matters
The new Union Customs Code (UCC) will come into force on 1 May 2016, repealing the old Code of 1992. Certain key measures should be taken into account in order