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
CbCR: situation of French subsidiaries of foreign entity residing in a state that does not apply the automatic exchange of information, example of Switzerland and the United States
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
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
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
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
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
Interests of bonds convertible into shares and VAT prorata
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
Permanent establishment – Intragroup supply of services
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
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
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
CbC Reporting: Situation of French Subsidiaries of American Groups
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
Exceptional surtax on corporate income tax for very large companies
On 2 November 2017, the French government presented to parliament an amended finance bill for 2017 that would introduce an exceptional one-time surtax on corporate income tax due from very
Simplification of the anti-fraud provision for cash-register software: publication of an FAQ
The publication of an FAQ by the French Administration answers some of the various questions asked by businesses following the simplification of this provision, now limited to cash-register software. In