The practical application of several transfer pricing methods involves comparing the profit of an enterprise (or one of its activities) with the profit of independent enterprises considered as “comparable”. The

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,

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

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

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

Taking over a distressed French business in the courts is a known (1985) and specific technique that has many advantages. This is known as a transfer of assets plan (“plan

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

Pursuant to the 2017 Finance Act, a monthly income tax withholding system for tax residents was adopted on December 20, 2016 and was due to apply as from January 1st, 2018.