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
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
/ Appeals ,
Audits ,
BEPS ,
Corporate Counsel ,
Corporate Taxes ,
Criminal Prosecution ,
EU ,
Foreign Subsidiaries ,
France ,
Google ,
Ireland ,
Non-Prosecution Agreements ,
OECD ,
Popular ,
Principal Place of Business ,
Search & Seizure ,
Settlement ,
Tax Authority ,
Tax Evasion ,
Tax Treaty ,
Value-Added Tax (VAT)