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
Case law WB Ambassador: storm warning on intra-group loans?
Creation of a procedure of hearing for anyone who can provide information on breaches relative to tax fraud and international tax evasion
Through communication right, the French tax authorities (FTA) had already the right to obtain documents held by thirds parties in order to establish tax base and to control the tax.
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
Two major changes in filing obligations are to be noted: The threshold above which a taxpayer should file the transfer pricing return(formulaire 2257 SD, Article 223 quinquies B du CGI)
End of exemption from surtax on distributions within tax-consolidated groups: no retroactive effect the French Government announced
The French Government has just announced that the end of the exemption from 3% surtax on distributions within tax consolidated groups will not have a retroactive effect.