What is the Update? US and French Authorities reach agreement on creditability of French CSG and CRDS taxes. Background: The United States generally allows a taxpayer to claim a foreign
US and French Authorities reach agreement on creditability of French CSG and CRDS taxes
This article was published on January 25, 2018 by the Bureau of National Affairs, Inc., Bloomberg Tax. We obtained consent of the Bureau of National Affairs, Inc., Bloomberg Tax to
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
In order to comply with OECD standards established in Action 13 of the BEPS project, the article 107 of the Finance law for 2018 updates the content of the transfer
As part of the BEPS project, the OECD is updating its applicable transfer pricing guidelines. One of the most controversial issues in this update is the use of profit split.
In its decision of July 7, 2017 (TA Paris, 7 July 2017, n°1607683, WB Ambassador), the TA of Paris retains a strict assessment of the provisions of article 212-I of
At the time of Paradise Papers’ revelations about numerous tax schemes involving large international groups, it is interesting to look back at the activism of the European Commission, which has
The French tax administration has officially indicated this morning that subsidiaries and PEs in France of foreign MNEs, including US groups, do not have to file a CbCR in France
On April 21st, 2017, the Full Court Federal Court of Australia (FCF) has given a ruling on the deductibility of intercompany interest expense paid by an Australian company (Chevron Australia
Monthly Income tax withholding for tax residents – Postponement of the implementation and study on impact for companies
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.
On 2 February 2017, the French tax authorities released the form 2258-SD that must be used for purposes of filing the country-by-country (CbC) report by groups falling within the scope