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Morhain Victor Camatta Enacted in mid-2019, the French Digital Services Tax (DST) is supposed to be temporary and to be repealed as soon as new appropriate...
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...