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...
12/14/2021 2:24:23 PM Valueclick case: Paris Administrative Court of Appeal finds French permanent establishment By Yves Rutschmann Victor Camatta In a decision dated 11 December 2020 (Valueclick case), previously covered in this blog, the French Administrative Supreme Court (Conseil...
7/30/2021 8:38:08 AM Non-resident French capital gains tax now compatible with EU principles (at least partially) By Victor Camatta Paul Cauchin As part of the French Amended Finance Bill for 2021, the French Parliament amended the French capital gains tax applicable to non-French...
7/21/2021 2:00:28 PM French tax treatment of the gains arising from “management packages”: a new era opened by the French Administrative Supreme Court? By Jean-Florent Mandelbaum Victor Camatta Adrien Soumagne On 13 July 2021, the French Administrative Supreme Court (Conseil d’Etat) handed down three important tax decisions which shed new light...
7/9/2021 3:50:58 PM French tax allowance for corporate equity: an aborted initiative By Jean-Florent Mandelbaum Victor Camatta The context In France, like in many other countries, debt financing will often be preferred by businesses as it generates, subject to...