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La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more
1. Types of Business Entities - • Description of the types of entities available in each jurisdiction through which to conduct business - Business may be conducted in France either through a French branch of a...more
En l'absence de convention particulière entre le nu-propriétaire et l'usufruitier de parts sociales, le dividende prélevé sur le produit de la vente de la totalité des actifs immobiliers d'une société civile immobilière (SCI)...more
1. Types of Business Entities - • Description of the types of entities available in each jurisdiction through which to conduct business - Business may be conducted in France either through a French branch of a foreign...more
The French government has announced emergency measures regarding taxes and social contributions in order to protect businesses from the impact of the crisis. Key Points: ..Businesses may request delays for the payment...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
French companies’ annual general shareholders’ meetings season usually begins in mid-March and ends in June. The agendas typically include approving the annual financial statements and deciding on the distribution of...more
A new double taxation treaty between France and Luxembourg was signed on 20 March 2018 (the “New Treaty”). This New Treaty will replace the current tax treaty dated 1 April 1958, as amended several times and for the last time...more
On 20 March 2018, the Governments of France and Luxembourg signed a new French- Luxembourg treaty (the “New Treaty”), which will have an impact for certain investments in French real estate. Several changes were...more
As recently announced, the French and Luxembourg governments are finalising a new double tax treaty between the two countries (the «DTT»). We outline below the key revisions and their potential impact. 1. Withholding...more
France Welcomes Foreign and Alternative Capital Providers with Latest Reform of Finance Sector - Long a cornerstone of the French banking system, the "French banking monopoly" largely prevents non-bank entities from...more
The French Finance Act for 2016 and Amending Finance Act for 2015 were enacted on December 30, 2015 (the “Acts”). Under the new legislation, the neutralization of the 5% add-backs on dividends within tax-consolidated groups...more
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