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...
2/21/2025 1:43:00 PM French Finance Bill for 2025 - what will be new for individuals? By Jean-Florent Mandelbaum Victor Camatta After a chaotic process marked by the no-confidence vote of the Government formed by the French Prime Minister Barnier in December 2024...
2/21/2025 12:21:13 PM French Finance Bill for 2025: what will be new for businesses? By Sébastien de Monès Victor Camatta After a chaotic process marked by the no-confidence vote of the Government formed by the French Prime Minister Barnier in December 2024...
7/31/2023 9:40:20 AM Purpose tests in anti-abuse or anti-avoidance provisions in France By Pierre-Henri Durand Victor Camatta There are multiple purpose tests across different parts of the French corporate income tax legislation pursuant to which the French tax...
7/26/2023 8:49:25 AM Beneficial ownership from a French perspective By Pierre-Henri Durand Victor Camatta Increasingly, the French tax authorities are making use of the beneficial ownership concept to deny withholding tax exemptions (or the...
7/13/2023 8:51:40 AM What is the impact of the artificial arrangement concept on the identification of an abuse of law? By Yves Rutschmann Ronan Vallerie Iris Makhlouf The French Administrative Supreme Court’s recent case law has effectively reduced the two abuse of law conditions to one in the case of...
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...
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...
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...
4/7/2020 12:00:00 AM COVID-19: Favourable tax measures in France are conditional for large companies By Franck Morhain Victor Camatta As previously announced, the French Ministry of Finance released guidelines on 2 April 2020 setting out the undertakings to be given by...
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...
1/24/2020 3:41:41 PM Postponement of the 2020 French DST instalments following discussions in Davos By Victor Camatta Franck Morhain The French Digital Services Tax (“French DST”) which was enacted in mid-2019 with effect from 1 January 2019 has been expected to...
12/3/2019 12:00:00 AM The US's reaction to France's DST By Slaughter and May In her recent post, Zoe Andrews suggested that, given the importance for the UK of securing a post-Brexit trade agreement with the US,...
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...