7/1/2025 9:25:42 AM French Digital Services Tax under Constitutional Review: Key opportunities and deadlines for taxpayers By Pierre-Henri Durand Ronan Vallerie Victor Camatta On 17 June 2025, the French Administrative Supreme Court (Conseil d’État) referred a preliminary question on the constitutionality of the...
5/28/2024 11:22:46 AM Tax Disputes Podcast: France By Zoe Andrews I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to...
5/10/2023 2:21:01 PM Incompatibility of French non-resident capital gains tax with free of movement of capital confirmed for the past and potentially for the future! By Franck Morhain Victor Camatta In a decision dated 20 October 2020, previously covered on this blog, the Administrative Court of Appeal of Versailles had ruled that the...
5/4/2023 9:39:01 AM The French Administrative Supreme Court provides clarifications on the French CFC regime in a non-EU context By Yves Rutschmann Victor Camatta In a decision dated 25 April 2022, the French Administrative Supreme Court has provided useful clarifications on the French CFC regime...
3/23/2023 2:35:05 PM The European principle of legality of taxation and some possible applications in a French context By Yves Rutschmann Ronan Vallerie Iris Makhlouf The principle of legality of taxation (or principle of fiscal legality) forms part of the legal order of the European Union (EU) as a...
1/17/2023 11:17:14 AM French National Financial Prosecutor’s Office releases new guidelines for implementing public interest judicial agreements By Guillaume Pellegrin Yves Rutschmann Arnaud Mailhos The French National Financial Prosecutor’s Office (Parquet National Financier - PNF) published new Guidelines on public interest judicial...
4/9/2021 10:49:08 AM French Administrative Supreme Court takes post-dated OECD commentaries into consideration in interpreting French-Irish double tax treaty By Yves Rutschmann Victor Camatta In its decision in the Valueclick Case on 11 December 2020, the French Administrative Supreme Court ruled on the existence of a permanent...
4/8/2021 1:05:58 PM To what extent can post-dated OECD commentaries be taken into account in interpreting a double tax treaty? By Maarten van der Weijden Yves Rutschmann Victor Camatta This question - which is of utmost importance as the OECD commentaries provide key insights to tax authorities, taxpayers and judges, on...
12/14/2020 12:00:00 AM Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent” By Victor Camatta Pierre-Marie Roch In a decision dated 11 December 2020 (no 420174), the French Administrative Supreme Court (Conseil d’Etat) overturned the decision of the...
11/17/2020 9:10:46 AM The discrimination introduced by the non-French resident capital gains tax is not covered by the EU standstill clause: timing is of the essence! By Franck Morhain Victor Camatta The Administrative Court of Appeal of Versailles has recently ruled that the capital gains tax charge applicable to non-residents on the...
10/26/2020 9:44:17 AM Can administrative guidelines fix a legal provision which is inconsistent with EU principles? By Victor Camatta Franck Morhain The French Administrative Supreme Court has recently ruled, in the context of the capital gains tax charge applicable to non-residents on...
10/22/2020 10:01:31 AM Postponed French DST installments will be due in December 2020 as OECD missed end of 2020 deadline By Franck Morhain Victor Camatta Enacted in mid-2019, the French Digital Services Tax (DST) is supposed to be temporary and to be repealed as soon as new appropriate...
3/30/2020 11:36:20 AM French COVID-19 measures: an update By Victor Camatta In France, additional measures that extend or suspend certain time limits have been implemented in response to COVID-19, and it was...
3/22/2020 12:00:00 AM Fiscal responses to COVID-19 By Tanja Velling Markus Ernst Guillermo Canalejo Andrea Manzitti Maarten van der Weijden Victor Camatta +3 more... Show less As countries ramp up social distancing measures to combat COVID-19, the economic costs of the virus spiral and the G7 leaders have called...
10/7/2019 10:12:20 AM Directors of large French companies may be presumed French tax resident By Sébastien de Monès Guillaume Wulfowicz The French Draft Finance Bill for 2020, as published on 27 September, includes a provision introducing a presumption that individuals...
9/27/2019 7:34:24 PM Automatic transfer of certain French tax cases to the Public Prosecutor By Franck Morhain Guillaume Pellegrin On 27 September, one of the key measures introduced by the recent Anti-Fraud Law (which was adopted by the French Parliament on 23...