On February 5, 2024, the French Supreme Tax Court (Conseil d’État) voided French tax authority guidelines from May 2023 that provided that shares acquired upon the exercise of founder stock options, or Bons de Souscription de...more
In a landmark decision of 11 December 2020 involving digital player Conversant (fka Valueclick), the French Supreme Tax Court (Conseil d’État) ruled that a French company can qualify as a dependent agent, and thus as a French...more
The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets.
Understand how new tax regulations transect...more
6/2/2020
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The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
2/11/2020
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The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
7/15/2015
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EU resident individual taxpayers who have paid French social taxes (contribution sociale généralisée (CSG), contribution au remboursement de la dette sociale (CRDS) and prélèvements sociaux) on France-originating real estate...more
The annual filing imposed on trustees must be submitted by 15 June on new, dedicated forms published by the French tax authorities, and in the French language.
...more