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Corporate Tax
Group Taxation
Office Dépôt decision: the principle of non-deductibility of shareholder costs at the level of the subsidiaries of a group
CbCR: situation of French subsidiaries of foreign entity residing in a state that does not apply the automatic exchange of information
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
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National Tax
French income tax withholding: Measure your readiness !
French income tax withholding: focus on foreign employers and secondees to France
2018 RTC Guide: towards more clarifications, in particular regarding the identification of the scope of eligible R&D activities
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International Tax
Brexit – The withdrawal agreement – VAT & customs aspects
Brexit: Deal or No Deal? A Snapshot of the immigration implications
Transfer pricing adjustments and customs: the Chinese example
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Transfer Pricing
European Commission Targets Member States’ Tax Rulings as Prohibited State Aid: Where Will it Lead?
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
Profit split: uncertainty remains
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BEPS – OECD/EU
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
Profit split: uncertainty remains
Taxation of the digital economy: new developments, but not yet over
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Individual Tax
Global Rewards
French social surtaxes: refund claim opportunities
Significant changes to french trust reporting obligations
French Equity Savings Plan (PEA) & Brexit – Which impact on funds invested in British securities?
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International Mobility
Posted workers into France: new provisions, however insufficient! (Decree and Circular of 4th June 2019)
Significant changes to french trust reporting obligations
Brexit: France is preparing for no-deal for British nationals
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Private Clients
Financial Services Reward Update – CRD V and CRR II
Tax domicile in France of French major companies’ corporate executives
European Union Prospectus Regulation for non EU issuers
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French Taxation
Tax domicile in France of French major companies’ corporate executives
French social surtaxes: refund claim opportunities
US and French Authorities reach agreement on creditability of French CSG and CRDS taxes
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Indirect Tax
French VAT
Skarpa Travel s.p. European case: important clarifications regarding the VAT Tour-Operating margin scheme (TOMS)
Supplies of goods and services on aircrafts
Recovery of VAT on costs incurred in the event of an unrealized transfer of securities
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European VAT
Skarpa Travel s.p. European case: important clarifications regarding the VAT Tour-Operating margin scheme (TOMS)
Morgan Stanley Case-Law (C-165/17), January 24th, 2019
Recovery of VAT on costs incurred in the event of an unrealized transfer of securities
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Bank, Finance, Insurance
Morgan Stanley Case-Law (C-165/17), January 24th, 2019
Scope of the VAT exemption applicable to transactions performed by insurance intermediaries
VAT treatment of groups of persons formed in the financial and insurance sectors
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Real Estate VAT
VAT qualification of a finance lease with an option to purchase
VAT deduction on intermediation expenses incurred in the frame of a sale subject to the VAT exemption regime of article 257 bis of the FTC
VAT election to be liable for VAT on rents
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E-Commerce
“YouTube” and “Netflix” tax: publication of the implementing decree
The Google case : lack of VAT establishment in France
Application of the VAT reduced rate to digital books
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Customs & Global Trade
Brexit – The withdrawal agreement – VAT & customs aspects
French Customs Authorities comments for exports performed by non-established companies
Circular of 20 April 2017, concerning the application of late interests in case of late payment of some customs receivables
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Research & Development
“CIR” Tax Scheme
Research Tax Credit – A disappointing “counter-expertise”
Research Tax Credit (RTC) claimed by a certified company: towards a broad appreciation of the amounts to be deducted
Finance bill for 2020 – Research Tax Credit (RTC): a proposal for decreasing operating expenses
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“CIR” and Public Debate
Research Tax Credit – A disappointing “counter-expertise”
Finance bill for 2020 – Research Tax Credit (RTC): a proposal for decreasing operating expenses
Debate on the orientation of public finances: the RTC in the Economic and Finance Ministry sights
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Intellectual Property
The French-style IP box: reform of the tax regime on the proceeds from the sale or licensing of patents (Art. 14 of the FLP – new Article 238 of the CGI)
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Governmental Tax Incentives
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
The 2017 Deloitte “Survey of Global Investment and innovation incentives” has been released
Tax incentives for research and innovation in France and worldwide
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Tax Controversy
Computerized Tax Audit
Computerized tax audit – 2016 Amending finance law
Accounting examination – 2016 Amending Finance Law
Certified cash register system & accounting/management software
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Tax Controversy
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
Capital gains on the disposal of equity holdings: calculation of the proportion of fees and charges
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Legal
Corporate Law
The pre-pack asset sale plan: an effective tool for taking over a distressed French business
Non-performing loans: in order to increase the effectiveness of bank securities in the event of outstanding debts
The national data protection authority (CNIL) has published its opinion on the draft bill amending the French data protection act for the implementation of the GDPR
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Public Law
Social contributions and penalties: changes introduced by the Social Security Financing Law for 2018
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Labour Law
Posting of workers in the framework of the provision of services: revision of the Directive of 16 December 1996
Calculation of profit-sharing challenged by the Unions: the French Supreme Court closes Pandora’s Box
FOCUS ON the French labor law reform: the new outlines of the text definitively adopted
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Industries
Financial Services
Interests of bonds convertible into shares and VAT prorata
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
VAT treatment of groups of persons formed in the financial and insurance sectors
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Real Estate
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
VAT qualification of a finance lease with an option to purchase
VAT deduction on intermediation expenses incurred in the frame of a sale subject to the VAT exemption regime of article 257 bis of the FTC
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Digital
Recovery of VAT on costs incurred in the event of an unrealized transfer of securities
The national data protection authority (CNIL) has published its opinion on the draft bill amending the French data protection act for the implementation of the GDPR
Taxation of the digital economy: new developments, but not yet over
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“CPF” Think Tank
Clara Maignan
Taj, Société d'Avocats
Clara Maignan
Taj, Société d'Avocats
France
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