Taj's Blog

Corporate Tax

Interests of bonds convertible into shares and VAT prorata

18 May 2018

The Supreme Court recalls the solution held by the CJEU in the EDM case (April 29, 2004; aff.C-77/01) according to which the annual grant by a holding company of remunerated

Permanent establishment – Intragroup supply of services

European Commission Targets Member States’ Tax Rulings as Prohibited State Aid: Where Will it Lead?

Customs value – Transfer pricing adjustments

The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations

Individual Tax

Finance Tax Act for 2018 Anticipate impact and renewed opportunity for qualified share schemes

New free shares acquisition gain regime (so-called “Macron II” regime) The free shares tax and social regime has been modified by the 2018 Finance Tax Act (adopted on December 30th,

Investment and business friendly: France’s much-awaited 2018 personal tax reform

Investment and business friendly: France’s much awaited 2018 personal tax reform

2018 Social Security Draft Bill: The employer contribution due on French qualified free shares may be set at 20% again

2018 tax proposals affecting employment announced

Indirect Tax

Interests of bonds convertible into shares and VAT prorata

18 May 2018

The Supreme Court recalls the solution held by the CJEU in the EDM case (April 29, 2004; aff.C-77/01) according to which the annual grant by a holding company of remunerated

Permanent establishment – Intragroup supply of services

Exempt Intra-Community supplies and chain transactions

VAT refund claim: in which circumstances a VAT credit denied by the FTA may be carried-forward on a further return?

Digitalization of paper invoices in France

Research & Development

Parliament adopts second amended finance bill for 2017 and finance bill for 2018

3 January 2018

On 21 December 2017, the French parliament adopted the second amended finance bill for 2017 and the finance bill for 2018. These finance laws—the first of President Macron—are intended to

Finance bill for 2018 and innovation: what’s up ?

The reimbursement of the RTC has to be requested by the parent company

RTC – A first degree case law against the eligibility of retirement benefits

The reimbursement of the RTC can be requested by the assignee of the RTC receivable

Tax Controversy

Capital gains on the disposal of equity holdings: calculation of the proportion of fees and charges

20 June 2017

Administrative Supreme Court Decision, June 14, 2017 For accounting periods ending on or after 31 December 2012, the 12% portion of fees and charges is assessed on the gross amount

CVAE – Tax consolidation litigation – Repayments can still be obtained

French VAT refund claims filed by EU businesses non-established in France under the “8^th VAT Directive” Refund procedure

Computerized tax audit – 2016 Amending finance law

Accounting examination – 2016 Amending Finance Law

Legal

Calculation of profit-sharing challenged by the Unions: the French Supreme Court closes Pandora’s Box

19 March 2018

The French Supreme Court (“Cour de cassation”) has just ruled on an important matter concerning statutory profit-sharing in a way which hampers attempts by staff representative bodies to challenge employers’