The French parliament adopted on 17 November 2020 the 2021 finance law. This article summarizes some of the law’s key provisions applicable to companies, some of which are the same
The French parliament adopted on 17 November 2020 the 2021 finance law. This article summarizes some of the law’s key provisions applicable to companies, some of which are the same
In a decision dated November 4, 2020 (no. 435295, “BNP Paribas Securities Services”), the French Administrative Supreme Court (Conseil d’Etat) has applied for the first time the “Skandia” case law
In the context of the current COVID19 economic crisis, the improvement of the cash position of the operating companies becomes a critical need. The 2021 draft French finance bill includes
By a 2017 ruling, the French State Council stated that the expenses of seconded staff carrying out research operations in the company premises and with its resources could be eligible
The administration benefits from the rebuttable presumption of indirect transfer of profits abroad if it demonstrates the existence of a “relationship of dependency” between a French entity and a foreign
Under OECD recommendations, jurisdictions should require, in a timely manner, the filing of Country-by-Country declarations by the ultimate parent companies of MNE group resident in their countries and exchange this
Lapeyre, Wolters Kluwer, Xerox, … The last two years have been marked by a new type of dispute, characterized by the incursion of the civil judge in the determination of
In order to benefit from the presumption of transfer of profits attached to article 57 of the French Tax Code (“FTC”), authorities must produce a double proof: Evidence of a
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
The Administrative Court of Appeal of Paris reminds that a permanent establishment may only be qualified, notwithstanding the main criteria of the head office, as the place of supply of