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French Tax Update - Recent Case Law And Other Noteworthy Publications
Literally "not twice in the same," non bis in idem is basically a legal doctrine whereby no legal action can be initiated twice for the same course of action.
5 Feb 2016
French Tax Update - Amending Finance Bill For 2015 And Noteworthy Q4 Case Law
The present French Tax Update contains (i) an overview of the main provisions proposed by the draft amending finance bill for 2015 (loi de finances rectificative pour 2015, 2015 Draft Amending Finance Bill)...
9 Dec 2015
French Tax Update - Recently Published Noteworthy Publications
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months...
9 Nov 2015
French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December, (ii) the amendment signed in March 2015 in respect of the France/Germany double tax treaty, and (iii) the decision issued in early September by the European Court of Justice in the Steria case.
9 Oct 2015
French Tax Update - Main French Tax Rates For 2015
This special French Tax Update provides an overview of the main tax rates applicable in France.
9 Sep 2015
Double Tax Treaties – Ratification Update
The Amendment will enter into force on the first day of the month following the completion of the reciprocal notification process attached to its ratification in each of France and Luxembourg.
21 Aug 2015
Form Vs. Substance
The FTA had denied the Exemption on the basis of the so-called "abuse of law" procedure, i.e., that the Sub had no other purpose than to "transform" taxable income into quasi tax-exempt dividends.
20 Aug 2015
Scope Of The Former 40 Percent Tax Basis Relief On Dividends - August 2015
Unlike the aforementioned QPC rulings, the Conseil Constitutionnel did not find the provisions of the FTC relating to the taxation of dividends received by individual shareholders fully compliant with the French Constitution.
19 Aug 2015
Exceptional Depreciation Of Industrial Assets
The Exceptional Depreciation will not be reflected under the French GAAP and will take the form of a tax adjustment to book entries.
4 Jun 2015
Scope Of The Former 40 Percent Tax Basis Relief On Dividends
The 40 percent tax relief on the amount of dividends received has been maintained.
4 Jun 2015
Exit Tax On Eligible Assets That Become Subject To The French Reit-Like Regime
Considering that such provisions had never been reviewed by the Conseil constitutionnel and could potentially create a breach of equality between taxpayers, the Conseil d'Etat requested a QPC from the Conseil constitutionnel.
4 Jun 2015
Retroactivity Of The Limitation On The Deductibility Of Capital Losses
In a nutshell, where the market value of such shares at the time of their issuance is lower than their book value, the difference may not be deducted from the taxable profits of the taxpayer at the time of the sale.
4 Jun 2015
Debt-Push-Down Challenged Under Abuse Of Law Theory
The French tax authorities challenged, under the abuse of law doctrine, the tax deduction of the interest payments made by FCo, on the grounds that the issuance of the ORAs was purely tax motivated.
3 Jun 2015
French Tax Update - Recent Noteworthy French Tax Court Decisions
For VAT purposes, the French case law generally considers that the "transactions" between a head office and its PE are not within the scope of the tax (i.e., because they take place within the same legal entity).
7 May 2015
French Tax Update - Noteworthy Tax Courts Decisions And Draft Macron Law
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron.
18 Mar 2015
German Constitutional Court Issues Ruling On Retroactivity Of Tax Laws
The German Constitutional Court (Bundesverfassungsgericht) issued a decision in respect to a tax law that had retroactive effect when it was enacted.
12 May 2014
French Tax Update - Anti-Hybrid Regime Draft Guidelines and Early 2014 Noteworthy Case Law
"French Tax Update" is a periodic publication that examines the French hot topics in the field of tax.
6 May 2014
Internal Revenue Code Section 336(e) Elections: Basic Overview
The U.S. Treasury Department recently issued final regulations allowing certain taxpayers to make a special election to treat a disposition of domestic company stock as a disposition of that company's assets for U.S. federal income tax purposes.
United States
23 Sep 2013
Possible Tax Arrangements In The Taxation Of "Stock Options"
Stock options are part of the "standard repertoire" in the compensation practice of large companies, particularly in the employment contracts of managing directors, board members, and other top executives.
30 Jul 2013
China´s New Administrative Regulation On Prepaid Corporate Income Tax For Real Estate Developers
On April 7, 2008, the State Administration of Taxation ("SAT") issued a circular governing provisional Corporate Income Tax ("CIT") payment issues for real estate developers [Guo Shui Han (2008) No. 299] ("Circular 299"), which is retrospectively effective from January 1, 2008.
18 Jun 2008
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